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10 February 2017 GST/HST Ruling 162056- Application of the GST/HST to an investment transaction-- summary under Subsection 182(1) Summary Under Tax Topics- Excise Tax Act- Section 182- Subsection 182(1) 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 consideration for the right to receive monthly royalties calculated as a percentage of intellectual property (IP) related revenue streams of Corporation 1. ... " CRA ruled that the lump sums so paid are consideration for the taxable supply to Investor of intangible personal property (the right to the royalty payments). ...

3 November 2009 GST/HST Interpretation 109447- Lease Surrender-- summary under Sale Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Sale surrender of leasehold interest was sale of real property The surrender of a lease to the landlord qualified as a demise of real property, so that s. 221(2)(b) and 228(4) applied to the consideration therefor paid by the landlord. ...

3 November 2009 GST/HST Interpretation 109447- Lease Surrender-- summary under Subsection 221(2) Summary Under Tax Topics- Excise Tax Act- Section 221- Subsection 221(2) surrender of realty lease is transfer of realty The surrender of a lease to the landlord qualified as a demise of real property, so that s. 221(2)(b) and 228(4) applied to the consideration therefor paid by the landlord. ...

CRA ruled that the Royalty Acquisition Amount is consideration for a taxable supply made by Corporation 1 of intangible personal property (a right to be paid money, that is, the Royalty Payments). ...