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The Original Agreement provided that, in consideration for the management services, Opco "shall pay to [Holdco] a management fee per annum equal to the total of (i) XXXXXXXXXX% of the net merchandise sales of [Opco], before taxes". ...

Il ne peut donc pas être pris en considération dans la situation présente. ...

Similarly, based upon our understanding of the ITRP as described above, it is our preliminary view, subject to consideration of the final arrangements and regulations relating thereto, that "royalty offsets" arising under the ITRP would also constitute "government assistance" within the meaning of 127(9) of the Act. ...

You also noted that the CICA Handbook, in section 3400, entitled Revenue, at paragraph.03, defines Revenue as: "... the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of an enterprise, normally from the sale of goods, the rendering of services, and the use by others of enterprise resources yielding interest, royalties and dividends. ...

The amount subject to installment payments is determined by whichever of the following methods* gives rise to the least total amount of installments of tax for the year: (a) the total of the taxes payable under Parts I, I.3, VI and VI.1 by the corporation for the year, determined before taking into consideration the "specified future tax consequences", within the meaning thereof in subsection 248(1) of the Act, for the year; (b) the corporation's first installment base for the year; or (c) the corporation's second installment base and its first installment base for the year. ...

Subsection 14(1) of the Act requires a consideration of whether an amount in respect of damage/compensation, had it been paid rather than received by a taxpayer, would be an "eligible capital expenditure" (i.e., the mirror principle). ...

One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction. ...

After consideration of the connecting factors, the Court found that the performance of her duties, being primarily for the Indians on reserve, the actual historical circumstances involving the relocation off reserve and Ms. ...

We do not have sufficient information to comment further on this point, but just raise the question for your consideration. ...

The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work [...], any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience [...] ...