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Miscellaneous severed letter
14 November 1990 Income Tax Severed Letter
You ask if the payment from such income of the following items would cause someone other than the spouse to be entitled to receive some of the income of the trust in contravention of subparagraph 73(1)(c)(i): (a) trustee's fees; (b) lawyer's and accountant's fees; or (c) taxes payable by the trust as a result of a subsection 104(13.1) designation. 2. Where an expenditure is not deductible in arriving at the income of the trust (e.g., a realtor's fees incurred on the acquisition of a building), you ask if the payment of that expenditure from the capital of the trust would cause someone other than the spouse to obtain the use of any income or capital of the trust in contravention of subparagraph 73(1)(c)(ii) of the Act. ...
Miscellaneous severed letter
5 May 1992 Income Tax Severed Letter - Registered retirement savings plans — promotional activities by bank
XXX Notwithstanding the XXX arguments, XXX and there was, therefore, a contravention of paragraph 146(2)(c.4). ...
Miscellaneous severed letter
7 October 1990 Income Tax Severed Letter - Loss of Status by Non-profit Organization
Our Comments In our view, where an organization that has non-profit status reacquires memberships or, as in the case of a stock exchange, seats at an amount greater than cost and the reacquisition is not financed out of capital gains of the organization it would be making income available to its members in contravention of paragraph 149(1)(l) of the Income Tax Act. ...
Miscellaneous severed letter
7 June 1991 Income Tax Severed Letter - Award of Damages
The cases involved allegations of a contravention of applicable Human Rights legislation. ...
Miscellaneous severed letter
4 March 1988 Income Tax Severed Letter 7-2563 - Payment by former employer pursuant to order of B.C. Council of Human Rights
The Council ordered the payment of the following amounts: (a) XXXX as compensation for wages lost by the taxpayer as a result of the contravention; and (b) XXXX in respect of humiliation and embarrassment. ...
Miscellaneous severed letter
7 August 1991 Income Tax Severed Letter - Meaning of Salary and Wages
If the monies are found to be other income includable under section 56 of the Act, XXX will not be in contravention of Regulation 6801 of the Act. ...
Miscellaneous severed letter
9 July 1986 Income Tax Severed Letter 5-1472 - []
Accordingly, since the Issuer described in each of the above situations pays (or credits) the cash bonuses or premium interest rates directly to the RRSPs (as opposed to paying these directly to the annuitants under the RRSPs) there is no contravention of the provisions of paragraph 146(2)(c.4) of the Act. ...
Miscellaneous severed letter
16 June 1989 Income Tax Severed Letter 5-7801 - Automobile allowances as relate to clergymen
As a result, any relief extended to this class of taxpayer would be in direct contravention to the Income Tax Act. ...
Miscellaneous severed letter
7 July 1990 Income Tax Severed Letter - Tax treatment of gifts of restrictive covenants
./1974, R-11; (c) run with the land and be binding on the landowner and his successors in title; (d) be enforceable by injunction to restrain any use in contravention of the covenant. ...
Miscellaneous severed letter
16 June 1989 Income Tax Severed Letter AC57801 - Application of Automobile Allowance to Clergymen
As a result, any relief extended to this class of taxpayer would be in direct contravention to the Income Tax Act. ...