Search - contravene

Puisque la structure proposée ne contrevient pas aux Lois et Règlements régissant la pratique de XXXXXXXXXX au Québec, la déduction des honoraires n'est pas refusée comme dépenses courantes dans le calcul du revenu d'entreprise du XXXXXXXXXX/ Since the proposed structure does not contravene the laws and regulations governing the practice of XXXXXXXXXX in Quebec, the deduction of fees will not be denied as a current expense in computing the XXXXXXXXXX business income. 2) Les salaires des XXXXXXXXXX sont une dépense déductible de la société de gestion/ The salaries of the XXXXXXXXXX are a deductible expense for the management corporation. ...

CRA Response Provided that the above scenario does not contravene the applicable corporate and trust laws, and that the common shares of Corporation Y held by Trust X have been received, directly or indirectly, from Corporation Y and are susceptible of reverting back to Corporation Y, subsection 75(2) ITA will apply so that any income or loss from the shares or from property substituted for the shares, or any taxable capital gain or deductible capital loss resulting from the disposition of the shares or of property substituted for the shares, will be deemed to be an income or loss, as the case may be, or a taxable capital gain or deductible capital loss, as the case may be, of Corporation Y. ...

Aco is unable to pay a dividend on the AA shares because it would contravene the solvency requirement under the Canada Business Corporations Act. ...

(e)In the event of a stock dividend, stock split, combination or exchange of shares, merger, consolidation, spin-off or other distribution (other than normal cash dividends) of XXXXXXXXXX assets to shareholders, or any other change affecting the XXXXXXXXXX Shares, such proportionate adjustments, if any, as the Personnel Committee of the Board of Directors in its discretion may deem appropriate to reflect such change, will be made with respect to the number of Units outstanding under the XXXXXXXXXX, provided (as confirmed in the above-referenced telephone conversation of XXXXXXXXXX) such proportionate adjustment does not contravene the condition in 5(i) below. ...

" Thus, even prior to the Kappus decision we recognized that the USAMT is not a "voluntary tax", as the U.S. government enforces the USAMT provisions despite the fact that these provisions contravene the Convention. ...

Clause XXXXXXXXXX contravenes Regulation 6801(a) which requires the Plan to be established for the main purpose of permitting the employee to fund, through salary or wage deferrals, a leave of absence from the employee’s employment. ...