directly related

30 September 2013 Internal T.I. 2012-0439661I7 - Income earmarked for future use & 95(2)(a)(i) -- summary under Subparagraph 95(2)(a)(i)

A CFA of Canco held funds generated from projects which were owned and operated by FA1, with the funds being "earmarked" for future investment in projects to be carried out by other CFAs of Canco. Earmarked funds for such future project investments which had been generated from existing projects also were held by FA2, which served as a principal global finance and treasury centre within the Canco group of companies, or by another CFA of a predecessor of Canco which previously had served that function.

By services, 28 November, 2015

Armada Equipment Corporation v. The Queen, 2007 DTC 879, 2007 TCC 260 (Informal Procedure) -- summary under Subsection 2900(2)

In finding that fees paid to an accounting firm to file claims for investment tax credits did not qualify as "directly related" to the prosecution of scientific research and experimental development, Mogan D.J. stated (at para. 15) that:

"In order to be 'directly related'', an expenditure must be incurred in the research itself or in the development itself. The amount paid to Deacur & Co. was a consequence of research and development which would already taken place."

directly related