The taxpayer, which assigned its franchise to supply municipalities with natural gas to another company in consideration for amounts (described in the assignment as "royalties") which were stipulated percentages of the revenues derived by the assignee from sales of gas, was held to receive the royalties as income pursuant to s. 3(1)(f) of the Income War Tax Act, which provided for the inclusion of "rents, royalties, annuities or other like periodical receipts which depend upon the production or use of any real or personal property". The payments were "royalties" in the business sense of that word in Canada, and dependent upon the use of the franchise.
Topics and taglines
Tagline
application to "royalty" participation in revenues generated from sold franchise
Words and phrases
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
333735
Extra import data
{
"field_legacy_header": "<a id=\"WainTown\"></a><strong><em>MNR v. Wain-Town Gas and Oil Co. Ltd.</em></strong>, 52 DTC 1138, [1952] CTC 147, [1952] 2 S.C.R. 377",
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"field_sid": "",
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}
"field_legacy_header": "<a id=\"WainTown\"></a><strong><em>MNR v. Wain-Town Gas and Oil Co. Ltd.</em></strong>, 52 DTC 1138, [1952] CTC 147, [1952] 2 S.C.R. 377",
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"field_sid": "",
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}