Words and Phrases - "royalties"
The Queen v. St. John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352 (FCA)
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...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 36 |
MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct)
Dumoulin J. stated (p. 1341):
"I incline to believe that a lump-sum payment for rights irrevocably ceded, tantamount to an assignment in...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 212 - Subsection 212(5) | 78 | |
Tax Topics - Income Tax Act - Section 212 - Subsection 212(5) | 63 | |
Tax Topics - Treaties - Income Tax Conventions - Article 12 | 60 |
Vauban Productions v. The Queen, 75 DTC 5371, [1975] CTC 511 (FCTD), aff'd 79 DTC 5186, [1979] CTC 262 (FCA)
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,...
Words and Phrases
royaltiesMobil Oil Canada Ltd. v. Canada, 2001 DTC 5668, 2001 FCA 333
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...
Words and Phrases
royaltiesMinister of National Revenue v. Wain-Town, 52 DTC 1138, [1952] CTC 147, [1952] 2 S.C.R. 377
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...
Words and Phrases
royalties