Munich Reinsurance Co. v. The Queen, 96 DTC 6185,  2 CTC 5 (FCTD)
Interest earned by the taxpayer (a German corporation carrying on a reinsurance business throughout the world, including through a branch in...
Twentieth Century Fox Film Corp. v. The Queen, 85 DTC 5513,  2 CTC 328 (FCTD)
All the film-rental revenues of the Canadian branch of the U.S. plaintiff were exempted from withholding tax by regulations 802 and 805(1), the...
|Locations of other summaries||Wordcount|
|Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii)||business conducted through agent/film distribution in Canada (without production) was Cdn business||188|
|Tax Topics - Income Tax Regulations - Regulation 805||film revenues were reasonably attributable to a Canadian distributorship business notwithstanding they were also attributable to U.S. movie production||191|