Search - contravention
Results 21 - 25 of 25 for contravention
Did you mean?convention
Article Summary
Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37 -- summary under Article 24
. …] Creditability where domestic Treaty override (p.9) Where the source state's domestic law expressly provides for taxation in contravention of a treaty, the treaty crediting mechanism would likely not apply (assuming the relevant treaty rule follows the OECD Model, which provides for a credit in respect of tax imposed "in accordance with the treaty"). ... The CRA appears to have accepted this premise in the context of U.S. alternative minimum tax imposed in contravention of the U.S. ... Arguably, this analysis could also be applied where foreign tax is imposed in contravention of a treaty under a domestic anti-treaty shopping rule. ...
Article Summary
Wertschek, "The Tax Advisor and Commercial Law: Some Issues", 1993 Conference Report, C. 24 -- summary under Dividend
Wertschek, "The Tax Advisor and Commercial Law: Some Issues", 1993 Conference Report, C. 24-- summary under Dividend Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Dividend Discussion (at pp. 9-12) of whether amounts paid as dividends in contravention of the governing corporate law will retain their character as dividends. ...
Administrative Policy summary
Memorandum D22-1-1 Administrative Monetary Penalty System, January 30, 2015 -- summary under Subsection 109.1(1)
CBSA post-release verification activities may identify multiple occurrences of an identical contravention. ... CBSA will not apply more than one AMPS contravention to any single instance of non-compliance. ... Most contraventions resulting from post release verifications have retention periods of three years; border related contraventions have a retention period of one year. ...
Administrative Policy summary
Master Penalty Document -- summary under Subsection 109.1(1)
Master Penalty Document-- summary under Subsection 109.1(1) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Customs Act- Section 109.1- Subsection 109.1(1) C353 Penalty 1st: $150 to a maximum of $5,000 (per issue) or $25,000 (per occurrence) 2nd: $225 to a maximum of $200,000 (per occurrence) 3rd and Subsequent: $450 to a maximum of $400,000 (per occurrence) Penalty basis: Per issue or per occurrence* Retention period: 36 months Contravention: Authorized person failed to pay duties as a result of required corrections to a declaration of value for duty within 90 days after having reason to believe that the declaration was incorrect Guidelines: * The term “per issue” applies to each element of the value for duty provisions that is incorrect and for which a correction was not made, regardless of how often the error is repeated on import documents. ... Non-compliance is normally discovered by a Senior Officer Trade Compliance (SOTC) as a result of an audit, examination, verification, or subsequent monitoring activity. … Contravention C353 applies only in cases where customs duties and/or taxes are payable by the importer as a result of the correction. ... Contravention C083 will not be applied in addition to this contravention. ...
Administrative Policy summary
25 February 2016 CBA Roundtable, Q. 9 -- summary under Section 285
The key factor to establish is whether the contravention of the ETA is the making of a false statement or omission in a return or whether it is the simple failure to file the return within the required time. ...