Louise Summerhill, Co-Chair of the Aird & Berlis LLP Tax Litigation Group, won the appeal in the Tax Court of Canada on behalf of Velcro Canada Inc. The CRA had argued that its Dutch parent, which was paid royalties for the use of intellectual property, was not the beneficial owner of the royalties and thus that the Canada-Netherlands Tax Treaty would not apply so that withholding tax was payable at the rate of 25%.