intangible property

By services, 11 May, 2019

Unidisc Musique Inc.v. Agence du revenu du Québec, 2019 QCCQ 1818, rev'd 2021 QCCA 393 -- summary under Paragraph 8(i)

The plaintiff (Unidisc) was in the business of purchasing master recordings of music (“masters”), i.e., the magnetic tapes containing the original recordings of the songs or other music, and making master copies of the masters for transmission to a studio for reproduction. Its revenues were principally derived from compilations which were sold as CDs or electronically.

1 March 2016 Internal T.I. 2016-0631181I7 - Specified foreign property - mineral rights -- summary under Specified Foreign Property

After noting that 2014-0522241I7 indicated that a right to mine for minerals in a mineral resource outside Canada falls within s. (b)(ii) of “foreign resource property” in s. 248(1), that “for such mineral right to be considered specified foreign property, the right would have to be tangible property, which is understood to include real property such as land and rights issuing out of, annexed to and exercisable within or about land,” and that the mineral right would be considered a tangible property coming within s.

intangible property