Cases
Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2
A Canadian corporation (“Sulpetro”), which had rights to direct the exploitation of, and to receive the proceeds from, a licence its U.K....
Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2
A Canadian corporation (“Sulpetro”), which had rights to direct and receive the proceeds from a licence its U.K. subsidiary (“SUKL”) held...
Placrefid Ltd. v. The Queen, 92 DTC 6480, [1992] 2 CTC 198 (FCTD)
A Canadian mortgagee of a Montreal property whose owner was in default granted the taxpayer, a non-resident corporation, an option to purchase...
The Queen v. Arnos, 82 DTC 6165, [1982] CTC 186 (FCA)
Since "recaptures of capital cost allowances are of the same nature as the revenue from the property in respect of which the capital cost...
See Also
Marin v. The Queen, 2022 TCC 49
Regarding a resident individual, who was assessed for Canadian income tax on income derived by him from a rental property in France, Lafleur J...
Resource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51
Art. VI of the Australia-U.S. Convention defined real property to include “rights to exploit or to explore for natural resources.” In...
Administrative Policy
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident
Mr. A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in...
1 February 2012 External T.I. 2011-0431571E5 - Canadian resource royalty received by US resident
oil royalty payments are covered by Art. VI, para. 2 of the Canada-US Convention ("amounts computed by reference to the amount or value of...