Valiant Cleaning Technology Inc. v. The Queen, 2008 DTC 5112, 2008 TCC 637 -- summary under Capital Loss v. Loss

Substantial advances which the taxpayer made to a U.K. subsidiary were made because the taxpayer's customer (Ford Motor Company) was requiring the taxpayer to operate on a global basis and the taxpayer feared that it would cease to be a major direct ("Tier 1") supplier to Ford if it did not maintain U.K. operations. As the advances were made in order to safeguard the taxpayer's stream of income from its Canadian business, the losses when sustained were currently deductible.