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”
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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
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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 105
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 264
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 207

Michael N. Kandev, "Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules", Tax Notes International, June 19, 2017, p.1087

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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
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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)

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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
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Words and Phrases
royalty

IT-303 "Know-How and Similar Payments to Non-Residents"

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Words and Phrases
royalty rent