SPG International Ltée v. R., [1998] 3 CTC 2046, 98 DTC 1706 (TCC) -- summary under Financing Expenditures

The taxpayer incorporated a U.S. subsidiary to facilitate the marketing of its goods in the U.S., and sold its goods to the subsidiary for on-sale to U.S. customers. Various expenses paid by the taxpayer including trade convention reservation fees, and travelling expenses incurred by the subsidiary's general manager, which were booked as advances by the taxpayer to the subsidiary, nonetheless were found to be currently deductible by the taxpayer since they were made for the purpose of promoting the sales of its products.