Symes v. Canada, 94 DTC 6001, [1993] 4 S.C.R. 695, [1994] 1 CTC 40 -- summary under Income-Producing Purpose

Before indicating that it was unnecessary to determine whether there should be a change in the traditional position that child care expenses (in this case, the expenses of a nanny paid by a mother who practised law full-time as a partner in a Toronto firm) were non-deductible, Iacobucci J. noted that the character of child care expenses was unique. Favouring their deductibility was the significant percentage of a taxpayer's income they represented, their general linkage to the taxpayer's ability to gain or produce income, and policy considerations (the expenditures are incurred as part of the development of another human life). On the other hand, such expenditures are also made in order to make a taxpayer available to the business.