Words and Phrases - "royalties"

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The Queen v. St. John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352 (FCA)

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 12
lump sum for indefinite right to use property not a royalty

Thurlow, C.J. stated (p. 6275) that "'royalties' ... connotes a payment calculated by reference to the use or to the production or revenue or...

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Words and Phrases
royalties rentals

MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct)

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d)

Dumoulin J. stated (p. 1341):

"I incline to believe that a lump-sum payment for rights irrevocably ceded, tantamount to an assignment in...

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Words and Phrases
royalties rent

Vauban Productions v. The Queen, 75 DTC 5371, [1975] CTC 511 (FCTD), aff'd 79 DTC 5186, [1979] CTC 262 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d)
royalties normally based on user

The non-resident taxpayer, a film distributor, which had acquired from another film distributor the distributorship rights for certain films,...

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Words and Phrases
royalties

Mobil Oil Canada Ltd. v. Canada, 2001 DTC 5668, 2001 FCA 333

Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(m)

Under the Road Allowances Crown Oil Act (Alberta), 1.88% of producing oil reservoirs of the taxpayer was deemed to be property of the Alberta...

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Words and Phrases
royalties

Minister of National Revenue v. Wain-Town, 52 DTC 1138, [1952] CTC 147, [1952] 2 S.C.R. 377

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g)
application to "royalty" participation in revenues generated from sold franchise

The taxpayer, which assigned its franchise to supply municipalities with natural gas to another company in consideration for amounts (described in...

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Words and Phrases
royalties