After noting that ss. “19, 19.01, and 19.1… limit or deny the deductibility of expenses for advertising in a broadcast or an issue of a newspaper or periodical when certain Canadian content or Canadian ownership requirements are not met,” CRA stated that it:
has considered the deductibility of Internet advertising expenses and concluded that the above-noted rules do not apply to the deductibility of advertising expenses on foreign Internet websites.
The Department of Finance…is aware of this issue and of the CRA’s position.