10 February 2017 Ruling 162056

Policy Tabs

Summaries

Summary Under

royalty agreement is not a debt security unless a minimum royalty is specified

Under Agreement 1, the Investor (a registrant) pays a lump-sum Royalty Acquisition Amount to Corporation 1 (a Canadian-resident registrant) in...

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Words and Phrases

Summary Under

the purchase of an IP royalty gives rise to non-creditable GST/HST to the investor

A Canadian registrant (Investor) enters into an agreement with a Canadian corporation (Corporation 1) under which it pays lump sums in...

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Summary Under

buyout of royalty agreement not subject to s. 182

A Canadian registrant (Investor) enters into “Agreement 1” with a Canadian corporation (Corporation 1) under which it pays lump sums in...

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Summary Under

receipt of royalty not considertion for a taxable supply

A Canadian registrant (Investor) enters into an agreement with a Canadian corporation (Corporation 1) under which it pays lump sums in...

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