Scheuermann, "Income and Commodity Tax Aspects of Acquiring and Exploiting Technology", 1991 Conference Report, c. 45.

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g)
Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d)
Summary Under
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14
Summary Under
Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1)
Summary Under
Tax Topics - Income Tax Regulations - Regulation 805

Discussion of the potential for double taxation where the non-resident does not have a permanent establishment in Canada, of the interplay with Regulation 802, and of the availability of a waiver.