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...
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 |
Vauban Productions v. The Queen, 75 DTC 5371, [1975] CTC 511 (FCTD), aff'd 79 DTC 5371, [1979] CTC 262 (FCA)
"The term 'royalties' normally refers to a share in the profits or a share or percentage of a profit based on user or on the number of units,...
Words and Phrases
royaltyGrand Toys Ltd. v. MNR, 90 DTC 1059 (TCC)
The taxpayer agreed to act as the exclusive distributor in Canada of articulated figurines produced by a Hong Kong joint venture ("Panosh") and...
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) | 69 |