Words and Phrases - "royalties"
The Queen v. St. John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352, 80 DTC 6272 (FCA)
Summary Under
Tax Topics - Treaties - Article 12Thurlow, 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 | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 36 |
Vauban Productions v. The Queen, 75 DTC 3571 (FCTD), aff'd 79 DTC 5186, [1979] CTC 262 (FCA)
The non-resident taxpayer, which had acquired from another film distributor the exclusive right for a limited period of time to show certain films...
Words and Phrases
royaltiesMNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538, 62 DTC 1338 (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 | |
|---|---|---|
| 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 - Article 12 | 60 |
Mobil 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
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