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This is evident from the various dictionary definitions of the word "royalty" when used in connection with a sum payable. ...

This is evident from the various dictionary definitions of the word "royalty" when used in connection with a sum payable. ...

This is evident from the various dictionary definitions of the word "royalty" when used in connection with a sum payable. ...

Commissioner of Internal Revenue, which you provided to us, in connection with the current case. ...

On the second question, it is possible that the connection between the corresponding adjustment and the 247(12) deemed dividend might be sufficient to conclude favorably because they both emanate from the transfer pricing primary adjustments negotiated by both Competent Authorities. ...

Any references or discussion in this document pertaining to the characterization of LLC2’s interest as FAPI or as ABI is in connection with the characterization of the income in respect of USP only. ...

R. 2004 DTC 6636 (FCA), the Court upheld the trial judge's reliance on factors such as operational control, economic dependence and family connections to conclude the same person had de facto control over two (2) corporations, which were deemed to be associated pursuant to subsection 256(1) of the ITA. ...