Bennett and White Construction Co. v. Minister of National Revenue, 49 DTC 514, [1949] CTC 1, [1949] S.C.R. 287, [1949-1950] DTC 514 -- summary under Financing Expenditures

Substantial annual fees paid by a construction company to its shareholders or related individuals in consideration for their providing guarantees of bank loans used by the company to finance its construction work were payments on account of capital and, therefore, non-deductible. Estey J. stated (at p. 9 (CTC)) that "this was not a borrowing of money on a temporary or short-term basis such as is necessary and incidental to the ordinary and usual transactions in the course of the appellant's business..."