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Decision summary
Jimenez, R. (On the Application of) v The First Tier Tribunal (Tax Chamber), [2019] EWCA Civ 51 -- summary under Paragraph 231.1(1)(d)
…It is sufficient that the sending of a taxpayer's notice to Mr Jimenez in Dubai has not been shown to contravene any international obligation of the UK. ...
Decision summary
Commissioner of Taxation v Addy, [2020] FCAFC 135, rev'd [2021] HCA 34 -- summary under Article 25
In finding that this 15% tax did not contravene Art. 25, Derrington J stated (at paras 230 and 231): Art 25 is offended where the discrimination against the foreign national occurs solely by reason of having a different nationality. ...
Ruling summary
2015 Ruling 2013-0513411R3 F - Société de professionnels -- summary under Income-Producing Purpose
The summary states: Since the proposed structure does not contravene the laws and regulations governing the practice of XX in Quebec, the deduction of fees will not be denied as a current expense in computing the XX business income. ...
Technical Interpretation - External summary
21 February 2013 External T.I. 2012-0442751E5 F - Non-Profit SR&ED corporation -- summary under Paragraph 149(1)(j)
Furthermore, paragraph XXXXXXXXXX of the Letters Patent, which provides that the Corporation may acquire and hold shares of corporations, must not contravene the criterion set out in paragraph 149(1)(j) to the effect that the corporation must not acquire control of another corporation. ...
News of Note post
CRA states: Participating in the CECRA with respect to commercial property held by a pension real estate corporation will not contravene the borrowing restriction in clause 149(1)(o.2)(ii)(C). Although participating in the CECRA by an RPP will contravene the narrower borrowing restriction in paragraph 8502(i), the CRA will exercise its discretion to not revoke the registration of an RPP for failure to comply with this condition. ...
News of Note post
(l) exclusion from the salary deferral arrangement definition after such a transfer, so that the FMV of the DSUs would be included in computing the employee's income in the year of the transfer (to the extent that such value had not already been included), CRA stated: A transfer to another person would contravene the preamble to paragraph 6801(d), which requires that the agreement be between the corporation and the employee and that it be that employee who may receive amounts under the arrangement. Furthermore … the transfer of the employee's rights in the DSU Plan could indirectly allow the individual to access the value of the individual's rights before one of the times specifically identified in paragraph 6801(d)(i) … which would also contravene the requirements of paragraph 6801(d). ...
" The summary contains the more helpful statement that: Since the proposed structure does not contravene the laws and regulations governing the [professional] practice… in Quebec, the deduction of fees will not be denied as a current expense. ...
The remedy restores the parties to an original oral bargain so that one party cannot rely on the strict terms of a written instrument that contravenes the true arrangement between the parties.” ...
News of Note post
In rejecting this position, Paris J referred to Article 1417 of the Civil Code (“A contract is absolutely null where the condition of formation sanctioned by its nullity is necessary for the protection of the general interest”), and stated that under the jurisprudence “a purpose which is contrary to the public order and which contravenes a penal provision, in the current case, of the Criminal Code, engages the absolute nullity of the contract” (here, an alleged partnership contract). ...
News of Note post
CRA recognizes the Galway principle, stating: Auditors cannot contravene provisions of the ITA or ETA in negotiating and finalizing an audit agreement. ...