Search - convention
Results 1 - 3 of 3 for convention
EC summary
MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct) -- summary under Article 12
., 62 DTC 1338, [1962] CTC 538 (Ex Ct)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A lump-sum payment made by a Canadian film distributor to a New York company for the acquisition of exclusive rights to exploit films was characterized as being a payment for the outright purchase of such films, and therefore for purposes of the old Canada-U.S. Income Tax Convention did not have the character of a royalty. ...
EC summary
Western Electric Co. Inc. v. MNR, 69 DTC 5204, [1969] CTC 274 (Ex Ct), briefly aff'd 71 DTC 5068 (SCC) -- summary under Article 12
MNR, 69 DTC 5204, [1969] CTC 274 (Ex Ct), briefly aff'd 71 DTC 5068 (SCC)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A U.S. ... Convention, Dumoulin J. indicated that he was in substantial agreement with the Crown's submission that the confidential information that was so supplied was, if not "secret processes", of precisely the same nature: it was valuable, jealously guarded proprietary information. ...
EC summary
MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct) -- summary under Subsection 212(5)
Income Tax Convention. ...