Search - contravention

22 October 2015 Internal T.I. 2013-0486491I7- Overdrafts in a TFSA Principal Issues: 1(a) Would an unintended short-term overdraft in a TFSA trust constitute “borrowing money or other property” in contravention of the prohibition in paragraph 146.2(2)(f)? ... (a) Would an unintended short-term overdraft in a TFSA trust constitute “borrowing money or other property” in contravention of the prohibition in paragraph 146.2(2)(f)? ... In the case of an overdraft in a TFSA, where it can be established that there is a lender/borrower relationship we would consider the TFSA trust to have “borrowed money or other property” in contravention of paragraph 146.2(2)(f). ...

Other options are available to the CRA in order to achieve the appropriate tax treatment of a transaction done in contravention of the trust instrument and the applicable law without necessarily relying on General Anti-Avoidance Rule (GAAR). ...

In our opinion, any arrangement which would allow an employee to receive any salary or wages from their employer for services performed during the period that the employee is on leave pursuant to an DSLP would be in contravention of subparagraph 6801(a)(iii) of the Regulations. ...

In our opinion, any arrangement which would allow an employee to receive any salary or wages from their employer for services performed during the period that the employee is on leave pursuant to an DSLP would be in contravention of subparagraph 6801(a)(iii) of the Regulations. ...

Under the program noted in your letter, the preferential pricing of financial products for some individuals was made conditional on the existence of an RRSP and, therefore, is a contravention of paragraph 146(2)(c.4) of the Act. ...

15 September 2020 External T.I. 2020-0854471E5- Pension Corporation- Renting Furnished Apartment Unedited CRA Tags 149(1)(o.2) Principal Issues: Whether the ownership of furniture used to furnish rental apartment units for students is a distinct activity separate from the activity of leasing real property in contravention of the activity restriction in clause 149(1)(o.2)(ii)(A). ...

En cas de contravention à cet engagement par M. B, la convention prévoit qu'il y a alors offre automatique et irrévocable de la part de Gesco de vendre ses actions de Opco à l'autre actionnaire (M. ... A propriétaire des actions de Opco détenues par Gesco si la "clause d'offre automatique" prévoit qu'en cas de contravention, M. ...