Williams Gold Refining Co. of Canada v. The Queen, 2000 DTC 1829 (TCC) -- summary under Capital Loss v. Loss

Debts owing by an affiliated company to the taxpayer that arose from the payment by the taxpayer of third-party expenses of the affiliate were found to be deductible on income account on the basis of evidence that the controlling shareholder's purpose in creating the affiliate was to improve the profitability of the taxpayer both by providing an expanded market for its products and by reducing its overhead costs.