MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct) -- summary under Paragraph 212(1)(d)

By services, 28 November, 2015

Dumoulin J. stated (p. 1341):

"I incline to believe that a lump-sum payment for rights irrevocably ceded, tantamount to an assignment in perpetuity ... can hardly be reconciled with the customarily accepted notion attaching to 'rent or royalties', id est: limit of time, retention of a 'jus in re' by the lessor, and periodical rentals by the lessee, either for fixed sums or an apportionment of receipts."

He also noted that the use of the word "rental" in the agreement, although not conclusive, afforded "some indication" that the payments were in the nature of rent.

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