Words and Phrases - "royalty"
29 October 2010 External T.I. 2009-0347791E5 F - Somme reçue par une société
A corporation ("Holdco") holding some of the voting shares of a corporation ("Opco") may receive amounts (contingent payments) from a non-resident...
16 August 2017 Internal T.I. 2017-0701291I7 - Exclusive Distributorship Rights
In consideration for a lump sum, a non-resident in a Treaty country (NRco) granted an arm’s length Canadian company (Canco) the exclusive right...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | Farmparts likely excluded application to product distributorship right/product name on product not a valuable use of trademark | 507 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | lump sum non-contingent payment for distributorship right was not a royalty | 120 |
| Tax Topics - Income Tax Act - Section 56.4 - Subsection 56.4(1) - Restrictive Covenant | a lump sum paid to a non-resident for granting an exclusive right to distribute its product in Canada was for a restrictive covenant | 279 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(i) | a lump sum paid to a non-resident for granting an exclusive right to distribute its product in Canada was subject to s. 212(1)(i) withholding | 216 |
16 August 2017 Internal T.I. 2017-0701291I7 - Exclusive Distributorship Rights
In consideration for a lump sum, a non-resident in a Treaty country (NRco) granted an arm’s length Canadian company (Canco) the exclusive right...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | Farmparts likely excluded application to product distributorship right/product name on product not a valuable use of trademark | 507 |
| Tax Topics - Income Tax Act - Section 56.4 - Subsection 56.4(1) - Restrictive Covenant | a lump sum paid to a non-resident for granting an exclusive right to distribute its product in Canada was for a restrictive covenant | 279 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(i) | a lump sum paid to a non-resident for granting an exclusive right to distribute its product in Canada was subject to s. 212(1)(i) withholding | 216 |
| Tax Topics - Treaties - Income Tax Conventions - Article 12 | lump sum paid for distributorship rights was not a royalty | 243 |
Michael N. Kandev, "Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules", Tax Notes International, June 19, 2017, p.1087
Potential non-existence of the situation posited (p. 1092)
[I]t is utterly mysterious how a rent or royalty can be determined, in whole or in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.8) - Specified Share | 71 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.6) - Paragraph 212(3.6)(a) | 85 |
6 February 2015 Internal T.I. 2015-0566681I7 F - Redevances perçues d'avance
In order that the non-capital losses of Lossco would not expire, an affiliated licensee of a licence to manufacture and sell a product made a...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | lump sum irrevocable prepayment of contingent future royalties fully included | 239 |
Grand Toys Ltd. v. MNR, 90 DTC 1059, [1990] 1 CTC 2165 (TCC)
The taxpayer agreed to act as the exclusive distributor in Canada of articulated figurines produced by a Hong Kong joint venture ("Panosh") and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 73 |
Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545
In order to divert to itself the increase in the price of oil that occurred after 1973, the Legislature of Saskatchewan enacted a "mineral income...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | 152 |
IT-303 "Know-How and Similar Payments to Non-Residents"
Meaning of royalty
7. The Department considers that the words "rent" and "royalty" are used in a broad sense and are not necessarily restricted to...