Clevite Development Ltd. v. MNR, 61 DTC 1093, [1961] CTC 147 (Ex. Ct.) -- summary under Business-Income Tax

Royalties received by the taxpayer from foreign patents were found to be income from a business rather than income from the mere holding of property notwithstanding that the taxpayer apparently had no business operations at the relevant times because the patents had previously been held in connection with a manufacturing operation of the taxpayer and the licence agreement required the licensor to assist the licensee (although such assistance, in fact, was provided by the foreign parent of the taxpayer).