Words and Phrases - "royalty"

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29 October 2010 External T.I. 2009-0347791E5 F - Somme reçue par une société

application of judicial definitions of “royalty”

A corporation ("Holdco") holding some of the voting shares of a corporation ("Opco") may receive amounts (contingent payments) from a non-resident...

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Words and Phrases
royalty

16 August 2017 Internal T.I. 2017-0701291I7 - Exclusive Distributorship Rights

lump sum paid for distributorship rights was not a royalty

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...

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Words and Phrases
royalty
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

lump sum non-contingent payment for distributorship right was not a royalty

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...

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Words and Phrases
royalty
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...

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Words and Phrases
royalty

6 February 2015 Internal T.I. 2015-0566681I7 F - Redevances perçues d'avance

irrevocable royalty prepayment under s. 12(1)(a) or 9

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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Words and Phrases
royalty
Locations of other summaries Wordcount
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...

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Words and Phrases
royalty

Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545

provincial tax styled as a direct "income tax" was in substance an ultra vires indirct tax on oil exports

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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Words and Phrases
royalty

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...

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Words and Phrases
royalty rent