What is the test for deductibility under the Business Corporations Act?
Canada (Federal), Canada
The following excerpt is from Graham v. Canada, 1997 CanLII 17778 (TCC):
Counsel referred to Symes v. Canada, 1993 CanLII 55 (SCC), 94 D.T.C. 6001 at p. 6009, 110 D.L.R. (4th) 470 (S.C.C.) and argued that the beginning point for deductibility is subsection 9(1) of the Act. Paragraph 18(1)(c) is a limiting section only. Subsection 9(1) embodies the business test for taxable profit. Thus in a deductibility analysis, one's first recourse is subsection 9(1).
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