MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct) -- summary under Subsection 212(5)

The taxpayer, which was a distributor of motion picture films in Canada, made various payments to non-residents for film rights including a lump-sum payment to a New York firm ("Sodak") for the exclusive right to exploit certain films. Notwithstanding that the lump-sum payment to Sodak was made for an outright purchase of film rights, such payment would have been subject to subsection 212(5) but for the application of the old Canada-U.S. Income Tax Convention.