for

Commissioner of Taxation v PepsiCo Inc, [2025] HCA 30 -- summary under Paragraph 212(1)(d)

Full Title
Commissioner of Taxation v PepsiCo Inc, [2025] HCA 30
Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d)
FMV sales proceeds of concentrate paid to an Australian sub of PepsiCo, the trademark licensor, not recharacterized as royalty

A U.S. company (“PepsiCo”) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
consideration
for
derived

Marin v. The Queen, 2022 TCC 49 -- summary under Non-Business-Income Tax

Full Title
Marin v. The Queen, 2022 TCC 49
Summary Under
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax
taxes for which FTC accorded must be imposed on the income which generates the Canadian taxes from which the credit is claimed

The taxpayer, a Canadian resident, was generally subject to French income tax on the rental income from a French property to the extent of his...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
for

Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65 -- summary under Subsection 105(1)

Full Title
Weyerhaeuser Company Limited v. The Queen, 2007 TCC 65
Summary Under
Tax Topics - Income Tax Regulations - Regulation 105 - Subsection 105(1)
no withholding on reimbursements for disbursements/no requirement for documentary support for allocations in NRs' invoices/travel time to Canada not re Cdn services

In 1998 the Canadian taxpayer paid $14.3 million to non-resident service providers in the ordinary course of its forestry business. The Minister...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
for
in respect of
retainer
fee
Subscribe to RSS - for