Stewart & Morrison Ltd. v. Minister of National Revenue, 72 DTC 6049, [1972] CTC 73, [1974] S.C.R. 477 -- summary under Capital Loss v. Loss

The taxpayer incorporated an American subsidiary to carry on its business in the U.S. and advanced the necessary funds for the subsidiary to carry on its business. The subsequent loss which the taxpayer sustained on these advances was a capital loss. Unlike the Berman case, where the taxpayer made voluntary payments to strangers for the purpose of protecting its business goodwill, here the payments were loans to a separate corporation.