TAXATION OF ROYALTIES IN AN INTERNATIONAL SETTING
by
Nathan Boidman
LECTURESHIP READING MATERIALS
Both the lecture notes and the Appendices will be augmented and/or completed by supplements (marked for ease of placement in hard copy binders made up by registrants) which will be released both (1) between the date of this first release and the date of the lecture and (2) after the lecture.
The Canadian IFA Branch has secured all necessary approvals to reproduce all materials in all the Appendices. To open the documents click on blue text in the title.
LECTURE PAPER
Taxation of Royalties in an International Setting – Part I
Taxation of Royalties in an International Setting – Part 2
Table of Appendices Accompanying Lecture Outline
Appendix 1 – Re Commercial Law Definitions of Royalties
Appendix 2 – CTJ Article by Duncan Osborne
Appendix 3 – CTF Paper by Geoffrey Walker
Appendix 5 – Re Paragraph 12(1)(g)
Appendix 21 – Re Paragraph 212(1)(d)
Appendix 22 – CRA on Paragraph 212(1)(d)
Appendix 23 – CRA on Scope of Subparagraph 212(1)(d)(iii)
Appendix 24 – The Surrogatum – In Lieu of Rule for Part XIII
Appendix 25 – Withholding Agent Factors (to come)
Appendix 26 – Her Majesty The Queen v. Saint John Shipbuilding & Dry Dock Co. Ltd.
Appendix 27 – Hasbro Canada Inc. v. Her Majesty The Queen
Appendix 28 – CRA on Shrink Wrap vs. Custom Software
Appendix 29 – CRA and Finance on OECD Views on Software
and Other “Digital” Property
Appendix 30 – Bundled Transactions
Appendix 31 – David Ward on the Role of OECD Model Treaty Commentaries
