Under a lease, the lessor retains residuary rights to the leased property. It was found that under the circumstances of the case, where there had...
The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.
The taxpayer transferred to the CBC certain film rights. Since the taxpayer did not transfer all its rights respecting the films to the CBC, the...
It was determined that there was a typographical error in the English version of the Canada-France Income Tax Convention (1951) in light of the...
Addy, J. indicated that he was "conscious" of the principle that "a liberal interpretation should be given to a tax convention".
Addy, J. stated (respecting Article 13 of the 1951 Canada-France Tax Convention): "The term 'royalties' normally refers to a share in the profits...
The non-resident taxpayer, a film distributor, which had acquired from another film distributor the distributorship rights for certain films,...
Email this Content