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Similarly, the appellant did not contravene the object and "Spirit of the relevant provisions of the Act by entering into a legal agreement, in accord with the facts, giving rise to real legal rights and obligations between the parties within the context of a valid business purpose. ... The position taken by counsel for the respondent is that even if the transactions are within the object and spirit of the legislation governing successor rules, thereby permitting the appellant to deduct the tax pools, then if allowed they would contravene the subsection by unduly or artificially reducing its income. ...

In the case before us, accepting this position would be tantamount to allowing the increase of Kruger's income for tax purposes brought about by the investment tax credits to be taxed once as regular income in its hands, and then, under the interpretation of subsection 55(2) put forward by the respondent, allowing a corresponding amount to be taxed again in the hands of the appellant, Kruco, as a capital gain, which clearly also contravenes the spirit of the provisions in issue. [85]          Since the increase in income caused by the investment tax credits was not notional enough not to result in additional tax, it should not be notional enough to justify an adjustment in determining safe income for the purposes of subsection 55(2) of the Act. [86]          As has been seen, the position of Revenue Canada (which has since become the Canada Customs and Revenue Agency) on phantom income goes very far, so far in fact that, in a technical interpretation dated December 15, 1999 (No. 9907635), it is stated that there could be an artificial creation of income, and thus a possible adjustment of safe income, where a corporation has not claimed capital cost allowance in certain years. ... At page 859, the Court held: Once again, I am not saying that the administrative interpretation could contradict a clear legislative text; but in a situation such as I have just outlined, this interpretation has real weight and, in case of doubt about the meaning of the legislation, becomes an important factor. [97]          Counsel for the appellant contended that the principle enunciated by the Supreme Court is applicable in the instant case, to the extent that the administrative policy set out in the form of Robertson's rules does not contravene the wording of the Act, and that this policy can validly be used in view of the ambiguous wording in the Act. [98]          Counsel for the appellant further relied on the reasons of the Quebec Court of Appeal in Sous-ministre du Revenu du Québec c. ...

Therefore, setting a value greater than $1 will not contravene the ratio set forth in The Queen v. ...

The appellant also contends that section 227.1 contravenes section 15 of the Charter on the basis that it treats the appellant as a director differently from other taxpayers. ...

Unless otherwise specifically provided, every person that contravenes a provision of this Act or the regulations is guilty of an offence and is liable to a minimum fine of $2,000 in the case of a natural person and $3,000 in other cases, double the profit realized or one fifth of the sums entrusted to or collected by the person, whichever is the greatest amount. ...

" "156.(2) A company that contravenes subsection (1) commits an offence and is liable to a fine not exceeding $50 for each day it is in default. ...

Statutory Provisions: Similar to Injunction   [5]      The relevant portions of subsection 188.2(2), (4) and (5) are as follows:               (2) The Minister may give notice by registered mail to a registered charity that the authority of the charity to issue an official receipt referred to in Part XXXV of the Income Tax Regulations is suspended for one year from the day that is seven days after the notice is mailed                   (a) if the charity contravenes any of sections 230 to 231.5; or               (2) Le ministre peut, par avis envoyé en recommandé, informer tout organisme de bienfaisance enregistré que son pouvoir de délivrer des reçus officiels, au sens de la partie XXXV du Règlement de l'impôt sur le revenu, est suspendu pour un an à compter du jour qui suit de sept jours l'envoi de l'avis si, selon le cas:               a) l'organisme a contrevenu à l'un des articles 230 à 231.5;   ...

However, the question remains, if the work was done, can it be said that this method of arranging one’s personal affairs contravenes the letter of the law as found within the relevant provision of the Act? ...

            (2)         A company that contravenes subsection (1) commits an offence and is liable to a fine not exceeding $50 for each day it is in default.. [16]     In the case of Pidskalny v. ...

Well, it's talking about transactions at non-arm's length where it's meant to contravene the legislation. ...