Excell Duct Cleaning Inc. v. The Queen, 2006 DTC 2040, 2005 TCC 776 -- summary under Capital Loss v. Loss

Sums which the taxpayer, a franchisor, advanced to another company ("991830") that was 2/3 owned by executives of the taxpayer and 1/3 owned by the individual operator of 991830 was found to give rise to a loss on income account when a 991830 terminated its operations, on the basis of a finding that the taxpayer made loans to various new franchisees in the ordinary course of its business activities in order to help the franchisees set up their businesses and thereby generate royalty income to the taxpayer.