See Also
LaRue v. MNR, 63 DTC 553, 32 Tax A.B.C. 281
The taxpayer, who was a professor of mathematics at Laval University, assigned the copyright in four textbooks that he had translated or written...
No. 682 v. MNR, 60 DTC 65, 23 Tax A.B.C. 300
The taxpayer, together with another senior government lawyer, agreed with a publisher to compile an encyclopedia of legal forms for total...
Shiner v. Lindblom (1960), 39 TC 367 (Ch. D.)
The taxpayer, who was a well-known actor, paid £200 for the film rights to a novel. On his later exercise of the option he acquired the rights...
Mackenzie v. Arnold (1952), 33 TC 363 (C.A.)
Royalties received by the taxpayer after becoming a U.K. resident that were in respect of novels that the taxpayer wrote while he was a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 54 | |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 54 |
Howson v. Monsell (1950), 31 TC 529 (HCJ)
A writer of historical fiction received amounts (payable in instalments) for the sale of film rights to two of her books. Because she received...
Withers v. Nethersole, [1948] 1 All E.R. 400, 28 TC 501 (HL)
The taxpayer who had the exclusive right to dramatize Rudyard Kipling's novel "The Light that Failed" later agreed with Mr. Kipling that Mr....
Glasson v. Rougier (1944), 26 TC 86 (KBD)
An author, who desired to raise substantial sums of money, agreed with her publishers that in consideration of £750 paid in three instalments she...
Hobbs v. Hussey (1942), 24 TC 153 (KBD)
The taxpayer, who was a solicitor's clerk who had never carried on the profession of an author, agreed with a newspaper publisher to write his...
Billam v. Griffith (1941), 23 TC 757 (KBD)
After finding that there was no basis for disturbing the finding of the Commissioners that a practising barrister was also carrying on the...
Beare v. Carter (1940), 23 TC 353 (KBD)
£150 that a practising lawyer received from an English publisher for permission to publish a 6th edition of his "History of the English Courts"...
Trustees of Earl Haig v. C.I.R. (1939), 22 TC 725 (CS (1st Div.))
The trustees of the estate of Earl Haig made an agreement with an author to make the diaries of the late Field Marshall available to him in...
Administrative Policy
10 May 2013 External T.I. 2013-0485501E5 - Disposition of Intellectual Property
In response to a question respecting the treatment of income received from the sale of intellectual property by a taxpayer that carries on a...
Commentary
Copyright royalties generally are income.
In addition, the sale of copyright (even if for a lump sum and entailing a transfer of all the rights to...