ABBOTT,
J.
(orally
for
the
Court)
:—It
will
not
be
necessary
to
hear
you,
Mr.
Bowman.
We
are
all
in
agreement
with
the
conclusion
reached
by
the
learned
trial
judge
that
the
payments
in
issue
on
these
appeals
(1)
come
within
the
provisions
of
Section
106(1)
(d)
of
the
Income
Tax
Act
and
(2)
were
rentals
or
royalties”
within
the
meaning
of
Article
II
of
the
Canada-U.S.
Tax
Convention
as
defined
in
Section
6(a)
of
the
Protocol.
The
appeals
are
therefore
dismissed
with
costs.
The
three
appeals
having
been
consolidated
for
hearing,
there
will
be
only
one
counsel
fee.
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