Western Electric Company Incorporated v. Minister of National Revenue, [1971] CTC 96, 71 DTC 5068

By services, 16 January, 2023
Is tax content
Tax Content (confirmed)
Citation
Citation name
[1971] CTC 96
Source
https://taxinterpretations.com/
Citation name
71 DTC 5068_1
Source
https://taxinterpretations.com/
Decision date
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
669941
Extra import data
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"field_full_style_of_cause": "Western Electric Company Incorporated, Appellant, and Minister of National Revenue, Respondent.",
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Style of cause
Western Electric Company Incorporated v. Minister of National Revenue
Main text

ABBOTT, J. (orally for the Court) :—It will not be necessary to hear you, Mr. Bowman. We are all in agreement with the conclusion reached by the learned trial judge that the payments in issue on these appeals (1) come within the provisions of Section 106(1) (d) of the Income Tax Act and (2) were rentals or royalties” within the meaning of Article II of the Canada-U.S. Tax Convention as defined in Section 6(a) of the Protocol.

The appeals are therefore dismissed with costs. The three appeals having been consolidated for hearing, there will be only one counsel fee.

Court
Supreme Court of Canada