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Technical Interpretation - Internal

6 July 2012 Internal T.I. 2012-0440741I7 - stock option benefit derived by US resident

Pursuant to subsection 227(8.1), where a taxpayer failed to deduct or withhold from a non-resident person in contravention of subsection 153(1), the non-resident person is jointly and severally liable with the taxpayer to pay any interest payable by the taxpayer under subsection 227(8.3). ...
Ruling

30 November 1995 Ruling 9634183 - SINGLE-WING BUTTERFLY OF PARTNERSHIP INTEREST

The redemption and purchase for cancellation by XXXXXXXXXX of its shares owned by XXXXXXXXXX as described in paragraph 14 above will not be in contravention of the limitations imposed by subsections 34(2) and 36(2) of the CBCA. ...
Technical Interpretation - Internal

1 March 1995 Internal T.I. 9423717 F - LEVER DU VOILE CORPORATIF ESPOIR RAISONNABLE DE PROFIT

., qui se lit ainsi: La personnalité juridique d'une personne morale ne peut être invoquée à l'encontre d'une personne de bonne foi, dès lors qu'on invoque cette personnalité pour masquer la fraude, l'abus de droit ou une contravention à une règle intéressant l'ordre public. ...
Technical Interpretation - Internal

28 April 2003 Internal T.I. 2003-0007327 - Barbados SRL

Subject to certain exceptions, an International/Exempt SRL may not: (a) acquire or hold land in Barbados, other than land required for its business held by way of lease or a tenancy agreement for a term not exceeding the period fixed in the articles for the duration of the society or such shorter period as circumstances require; (b) transact business with any person resident in Barbados; (c) take deposits from any person in contravention of the Financial Institutions Act. ...
Technical Interpretation - Internal

28 April 2003 Internal T.I. 2003-0007347 - Barbados SRL

Subject to certain exceptions, an International/Exempt SRL may not: (i) acquire or hold land in Barbados, other than land required for its business held by way of lease or a tenancy agreement for a term not exceeding the period fixed in the articles for the duration of the society or such shorter period as circumstances require; (ii) transact business with any person resident in Barbados; (iii) take deposits from any person in contravention of the Financial Institutions Act. ...
Ruling

2001 Ruling 2001-0112713 - PRESCRIBED PHANTOM SHARE PLAN

Reasons: The amendments will not result in any contravention of the provisions of paragraph 6801(d). ...
Miscellaneous severed letter

15 January 1992 Income Tax Severed Letter 249

A second issue in this case related to whether the taxpayer's equality rights as a parent and as a woman were violated in contravention to subsection 15(1) of the Charter of Rights. ...
Archived CRA website

ARCHIVED – Technical Amendments

Registered charities that return donated property may still be found to have made a gift to a non-qualified donee, in contravention of the Income Tax Act. ...
Old website (cra-arc.gc.ca)

Registered Users

The use of non-duty-paid packaged spirits by a registered user in any manner or process other than as described in paragraph 12 of this memorandum is a contravention of the Act. 15. ...
Current CRA website

3.1.3 Registered Users

The use of non-duty-paid packaged spirits by a registered user in any manner or process other than as described in paragraph 12 of this memorandum is a contravention of the Act. 15. ...

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