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20 November 1991 Income Tax Severed Letter F

Les circonstances déclenchant ainsi l'offre de vente des actions d'un actionnaire, peuvent, selon la volonté des actionnaires, couvrir plusieurs situations: a) l'invalidité permanente b) la retraite automatique à compter d'un âge prédéterminé c) l'inaptitude (anciennement "l'interdiction") d) la cessation du travail au service de la compagnie e) le manquement à un engagement de non-concurrence f) la fraude, le vol ou le détournement à l'encontre de la compagnie g) la faillite personnelle de l'actionnaire h) le changement du contrôle d'un actionnaire corporatif i) la contravention à une disposition de la convention j) le décès d'un actionnaire, etc. ...

8 October 2004 GST/HST Ruling 53262 - Timeshare Resort Points / Default by Purchasers of Points

Furthermore, the Administrative Monetary Penalty System (AMPS) applies to contraventions of the Customs Act, the Customs Tariff and the Special Import Measures Act and the respective regulations, as well as contraventions of the terms and conditions of licensing agreements and undertakings. ...

11 January 2005 GST/HST Interpretation 54061 - Clarification of Band-Empowered Entities (BEEs): the status of XXXXX

Can you confirm that there is no civil sanction against a financial institution unless it advances funds to a tax debtor in contravention of the notice issued under subsection 317(2) of the ETA? ...

22 July 1997 General Information Letter 11590-0611710-0111735-1 - General Information Letter

Subsection 82(3) states that a person who pays an administrative penalty in respect of a contravention may not be charged under the XXXXX with an offense (i.e., under section 80) in respect of that contravention. ...

Delegation under the

Subsection 147(14.1) May revoke the registration of a DPSP if a loan or benefit has been extended in contravention of paragraph 147(2)(k.1) of the Act and give notice of the effective date of the revocation Headquarters Positions Director General, Registered Plans Directorate History: Delegation in respect of subsection 147(14.1) was amended on June 16, 2004. ...

Income Tax Act – Authorization to exercise powers or perform duties of the Minister of National Revenue

Subsection 147(2) Deferred profit sharing plan (DPSP)- May form an opinion that a profit sharing plan meets the conditions of this subsection and register the plan Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Subsection 147(2.2) May extend the time a DPSP has to satisfy the requirements of paragraph 147(2)(i.1) Headquarters Positions Director General, Registered Plans Directorate Subsection 147(3) May accept an employees profit sharing plan (EPSP) for registration where all the required capital gains and losses have been allocated Headquarters Positions Director General, Registered Plans Directorate Subsection 147(4) On request may determine the amount of capital gains and losses of an EPSP Headquarters Positions Director General, Registered Plans Directorate Subsection 147(9) May permit in writing an amount to be deducted where the requirements of subsection 147(5.1) have not been satisfied Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Subsection 147(14) May revoke the registration of a profit sharing plan and give notice thereof Headquarters Positions Director General, Registered Plans Directorate Subsection 147(14.1) May revoke the registration of a DPSP if a loan or benefit has been extended in contravention of paragraph 147(2)(k.1) and give notice of the effective date of the revocation Headquarters Positions Director General, Registered Plans Directorate Subsection 147(22) May provide in writing that an amount transferred from a deferred profit sharing plan is not deemed to have been transferred contrary to subsection 147(19) Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Subsection 147.1(1)- Paragraph (c) of the definition "compensation" May accept an amount in respect of remuneration received while a non-resident Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Subsection 147.1(2) Registered pension plan (RPP)- May accept a pension plan for registration where the requirements of this subsection are met and may specify in writing the date of registration Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Subsection 147.1(4) May accept an amendment to an RPP where the requirements of this subsection are met Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Subsection 147.1(5) May impose reasonable conditions applicable to RPPs Headquarters Positions Director General, Registered Plans Directorate Subsection 147.1(6) RPP- May permit in writing the person or a majority of the persons who constitute the body of the administrator to be not resident in Canada Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Paragraph 147.1(10)(a) Defined Benefit RPP- Past service benefits- May certify in writing that prescribed conditions have been met Headquarters Positions Director General, Registered Plans Directorate Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Paragraph 147.1(10)(b) Defined Benefit RPP- Past service benefits- May accept a past service event Headquarters Positions Director General, Registered Plans Directorate Subsection 147.1(11) May give notice of intent to revoke an RPP Headquarters Positions Director General, Registered Plans Directorate Subsection 147.1(12) May give notice of revocation of an RPP Headquarters Positions Director General, Registered Plans Directorate Subsection 147.1(14) Multi-employer plans (MEP)- May give notice in writing to the administrators of two or more MEPs that each of the MEPs is deemed to be a multi-employer plan that is not a specified multi-employer plan Headquarters Positions Director General, Registered Plans Directorate Paragraph 147.2(2)(b) May approve an actuarial recommendation for required contributions to defined benefit provisions Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Subsection 147.2(3) May stipulate what information an actuarial report requires for purposes of 147.2(2) Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Paragraph 147.3(7.1)(e) May accept a transfer from a money purchase provision of an RPP to a money purchase provision of another RPP and notify the administrator of the transferor plan in writing Headquarters Positions Director General, Registered Plans Directorate Subsection 147.3(8) May accept a transfer from a registered pension plan and notify, in writing, the administrator of the transferor plan Headquarters Positions Director General, Registered Plans Directorate Subsection 147.3(13) Excess transfer- May in writing provide that a portion of an amount transferred was transferred in accordance with subsections 147.3(1) and (2) Headquarters Positions Director General, Registered Plans Directorate Paragraph 147.4(1)(d) May waive the application of paragraph 147.4(1)(d) with respect to a RPP annuity contract and notify the administrator of the plan in writing Headquarters Positions Director General, Registered Plans Directorate Subsection 147.5(2) May accept an arrangement under which property is held in connection with a pooled pension plan, form an opinion about whether the plan complies with conditions for registration and accept the plan for registration Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Subsection 147.5(6) May, in writing, impose additional reasonable conditions Headquarters Positions Director General, Registered Plans Directorate Subsection 147.5(7) May accept an amendment to a pooled registered pension plan (PRPP) Headquarters Positions Director General, Registered Plans Directorate Director, Registered Plans Directorate Manager, Registered Plans Directorate Officer, Registered Plans Directorate Subsection 147.5(24) May, in writing, give notice of intent to revoke a PRPP Headquarters Positions Director General, Registered Plans Directorate Subsection 147.5(26) May, in writing, give notice of a revocation of a PRPP Headquarters Positions Director General, Registered Plans Directorate Subsection 147.5(28) May, on the written request of the administrator of a PRPP, give notice of revocation Headquarters Positions Director General, Registered Plans Directorate Paragraph 149(1)(l) Non-profit organizations- May determine whether a club, society or association was not a charity within the meaning of subsection 149.1(1) Headquarters Positions Director General, Charities Directorate Director General, Compliance Programs Branch Director, Charities Directorate Director, Compliance Programs Branch Manager, Compliance Programs Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office History: Delegation in respect of paragraph 149(1)(l) was amended on October 19, 2020. ...

False or exaggerated business claims

Charles was notified by the Canada Revenue Agency (CRA) that reporting losses on behalf of his clients without sufficient supporting documentation was in contravention of the Income Tax Act. ...

10 March 2011 External T.I. 2010-0390061E5 - Pakistani withholding tax - 126(2)

In order to establish the legitimacy of the tax levied, we are generally of the view that Canco would have to have pursued all of the administrative avenues (e.g. objection, appeal, review) that it can regarding the tax assessed in contravention of a reasonable application of the Convention under Canadian law. ...

24 September 1997 External T.I. 9723695 F - LIQUIDATION

Réponse du ministère des Finances Le ministère des Finances entend bel et bien recommander des changements à l’alinéa 88(1)c.3) qui auraient pour effet de corriger les problèmes notés dans les trois exemples cités, de sorte que les contraventions décrites ne constituent pas par elles-mêmes des entraves à la majoration fiscale des biens distribués à une société mère lors de la liquidation de la filiale. ...

6 May 1996 Internal T.I. 9610546 - WORKERS COMPENSATION PAYMENT - ALBERTA

In our view, the relevant provisions in this case are as follows: 17(1) If an accident happens to a worker entitling him or his dependants to compensation under this Act and the circumstances of the accident are such as to also entitle the worker, his legal personal representatives or his dependants to an action against some person other than an employer or worker in an industry to which this Act applies in respect of the personal injury to or death of the worker, the Board is subrogated to the rights of the worker, his legal personal representatives or his dependants in respect of that cause of action. (2) When the Board becomes subrogated to the rights of a worker, his legal personal representatives or his dependants under subsection (1), (a) no payment or settlement shall be made to or with the worker, his legal personal representatives or his dependants for or in respect of those rights or for or in respect of any claim, cause of action or judgement arising out of them except with the consent of the Board, and any payment or settlement made in contravention of this clause is void, (b) an action against any person arising out of injury to or the death of the worker may, with the consent of the Board and on the terms that are satisfactory to the Board, be taken by the worker, his legal personal representatives or his dependants, or by the Board in the name of the worker, his legal personal representatives or his dependants, without the consent of the person in whose name the action is taken,.... (3) If the Board gives its consent under subsection 2(b), the legal costs incurred on behalf of the worker, his legal personal representatives or his dependants in taking the action shall be paid by the Board in the amount prescribed in the regulations unless the legal representative of the worker, or the worker's legal personal representatives or dependants satisfy the Board that that amount is insufficient, in which case the Board may increase the amount...... (5) If money is received by the Board because it is subrogated to the rights of a worker, his legal personal representatives or his dependants,.... ...

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