After stating (at p. 2263) that "if the payment is determined irrespective of the use of the licensed property it may well be a payment in the nature of a capital payment", Lamarre Proulx J. went on to find that minimum fee amounts received by the taxpayer for the grant of a 99-year exclusive software licence were based on the use of the licensed property and, accordingly, were income payments.
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Drupal 7 entity type
Node
Drupal 7 entity ID
339292
Extra import data
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