II, s. 141995, c. 46, s. 52001, c. 17, s. 112007, c. 35, s. 13
19.01(1)The definitions in this subsection apply in this section.advertisement directed at the Canadian marketadvertisement directed at the Canadian markethas the same meaning as the expressiondirected at the Canadian marketin section 2 of theForeign Publishers Advertising Services Actand includes a reference to that expression made by or under that Act. (annonce destinée au marché canadien)original editorial contentoriginal editorial contentin respect of an issue of a periodical means non-advertising content(a)the author of which is a Canadian citizen or a permanent resident of Canada within the meaning assigned by theImmigration Actand, for this purpose, “author” includes a writer, a journalist, an illustrator and a photographer; or(b)that is created for the Canadian market and has not been published in any other edition of that issue of the periodical published outside Canada. (contenu rédactionnel original)periodicalperiodicalhas the meaning assigned by section 2 of theForeign Publishers Advertising Services Act. (périodique)Marginal note:Limitation re advertising expenses — periodicals(2)Subject to subsections (3) and (4), in computing income, no deduction shall be made by a taxpayer in respect of an otherwise deductible outlay or expense for advertising space in an issue of a periodical for an advertisement directed at the Canadian market.Marginal note:100% deduction(3)A taxpayer may deduct in computing income an outlay or expense of the taxpayer for advertising space in an issue of a periodical for an advertisement directed at the Canadian market if(a)the original editorial content in the issue is 80% or more of the total non-advertising content in the issue; and(b)the outlay or expense would, but for subsection (2), be deductible in computing the taxpayer’s income.Marginal note:50% deduction(4)A taxpayer may deduct in computing income 50% of an outlay or expense of the taxpayer for advertising space in an issue of a periodical for an advertisement directed at the Canadian market if(a)the original editorial content in the issue is less than 80% of the total non-advertising content in the issue; and(b)the outlay or expense would, but for subsection (2), be deductible in computing the taxpayer’s income.Marginal note:Application(5)For the purposes of subsections (3) and (4),(a)the percentage that original editorial content is of total non-advertising content is the percentage that the total space occupied by original editorial content in the issue is of the total space occupied by non-advertising content in the issue; and(b)the Minister may obtain the advice of the Department of Canadian Heritage for the purpose of(i)determining the result obtained under paragraph (a), and(ii)interpreting any expression defined in this section that is defined in theForeign Publishers Advertising Services Act.Marginal note:Editions of issues(6)For the purposes of this section,(a)where an issue of a periodical is published in several versions, each version is an edition of that issue; and(b)where an issue of a periodical is published in only one version, that version is an edition of that issue.
(a)the author of which is a Canadian citizen or a permanent resident of Canada within the meaning assigned by theImmigration Actand, for this purpose, “author” includes a writer, a journalist, an illustrator and a photographer; or(b)that is created for the Canadian market and has not been published in any other edition of that issue of the periodical published outside Canada. (contenu rédactionnel original)
(a)the original editorial content in the issue is 80% or more of the total non-advertising content in the issue; and(b)the outlay or expense would, but for subsection (2), be deductible in computing the taxpayer’s income.
(a)the original editorial content in the issue is less than 80% of the total non-advertising content in the issue; and(b)the outlay or expense would, but for subsection (2), be deductible in computing the taxpayer’s income.
(a)the percentage that original editorial content is of total non-advertising content is the percentage that the total space occupied by original editorial content in the issue is of the total space occupied by non-advertising content in the issue; and(b)the Minister may obtain the advice of the Department of Canadian Heritage for the purpose of(i)determining the result obtained under paragraph (a), and(ii)interpreting any expression defined in this section that is defined in theForeign Publishers Advertising Services Act.
(i)determining the result obtained under paragraph (a), and(ii)interpreting any expression defined in this section that is defined in theForeign Publishers Advertising Services Act.
(a)where an issue of a periodical is published in several versions, each version is an edition of that issue; and(b)where an issue of a periodical is published in only one version, that version is an edition of that issue.
[NOTE: Application provisions are not included in the consolidated textsee relevant amending Acts and regulations.]2001, c. 17, s. 12
19.1(1)Subject to subsection 19.1(2), in computing income, no deduction shall be made in respect of an otherwise deductible outlay or expense of a taxpayer made or incurred after September 21, 1976 for an advertisement directed primarily to a market in Canada and broadcast by a foreign broadcasting undertaking.Marginal note:Exception(2)In computing income, a deduction may be made in respect of an outlay or expense made or incurred before September 22, 1977 for an advertisement directed primarily to a market in Canada and broadcast by a foreign broadcasting undertaking pursuant to(a)a written agreement entered into on or before January 23, 1975; or(b)a written agreement entered into after January 23, 1975 and before September 22, 1976 if the agreement is for a term of one year or less and by its express terms is not capable of being extended or renewed.Marginal note:Definitions(4)In this section,foreign broadcasting undertakingforeign broadcasting undertakingmeans a network operation or a broadcasting transmitting undertaking located outside Canada or on a ship or aircraft not registered in Canada; (entreprise étrangère de radiodiffusion)networknetworkincludes any operation involving two or more broadcasting undertakings whereby control over all or any part of the programs or program schedules of any of the broadcasting undertakings involved in the operation is delegated to a network operator. (réseau)
(a)a written agreement entered into on or before January 23, 1975; or(b)a written agreement entered into after January 23, 1975 and before September 22, 1976 if the agreement is for a term of one year or less and by its express terms is not capable of being extended or renewed.
[NOTE: Application provisions are not included in the consolidated textsee relevant amending Acts and regulations.]1974-75-76, c. 106, s. 31977-78, c. 1, s. 131985, c. 45, s. 126(F)
20(1)Notwithstanding paragraphs 18(1)(a), 18(1)(b) and 18(1)(h), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable theretoMarginal note:Capital cost of property(a)such part of the capital cost to the taxpayer of property, or such amount in respect of the capital cost to the taxpayer of property, if any, as is allowed by regulation;Marginal note:Incorporation expenses(b)the lesser of(i)the portion of the amount (that is not otherwise deductible in computing the income of the taxpayer) that is an expense incurred in the year for the incorporation of a corporation, and(ii)$3,000 less the total of all amounts each of which is an amount deducted by another taxpayer in respect of the incorporation of the corporation;Marginal note:Interest(c)an amount paid in the year or payable in respect of the year (depending on the method regularly followed by the taxpayer in computing the taxpayer’s income), pursuant to a legal obligation to pay interest on(i)borrowed money used for the purpose of earning income from a business or property (other than borrowed money used to acquire property the income from which would be exempt or to acquire a life insurance policy),(ii)an amount payable for property acquired for the purpose of gaining or producing income from the property or for the purpose of gaining or producing income from a business (other than property the income from which would be exempt or property that is an interest in a life insurance policy),(iii)an amount paid to the taxpayer under(A)an appropriation Act and on terms and conditions approved by the Treasury Board for the purpose of advancing or sustaining the technological capability of Canadian manufacturing or other industry, or(B)theNorthern Mineral Exploration Assistance Regulationsmade under an appropriation Act that provides for payments in respect of the Northern Mineral Grants Program, or(iv)borrowed money used to acquire an interest in an annuity contract in respect of which section 12.2 applies (or would apply if the contract had an anniversary day in the year at a time when the taxpayer held the interest) except that, where annuity payments have begun under the contract in a preceding taxation year, the amount of interest paid or payable in the year shall not be deducted to the extent that it exceeds the amount included under section 12.2 in computing the taxpayer’s income for the year in respect of the taxpayer’s interest in the contract,or a reasonable amount in respect thereof, whichever is the lesser;Marginal note:Compound interest(d)an amount paid in the year pursuant to a legal obligation to pay interest on an amount that would be deductible under paragraph 20(1)(c) if it were paid in the year or payable in respect of the year;Marginal note:Expenses re financing(e)such part of an amount (other than an excluded amount) that is not otherwise deductible in computing the income of the taxpayer and that is an expense incurred in the year or a preceding taxation year(i)in the course of an issuance or sale of units of the taxpayer where the taxpayer is a unit trust, of interests in a partnership or syndicate by the partnership or syndicate, as the case may be, or of shares of the capital stock of the taxpayer,(ii)in the course of a borrowing of money used by the taxpayer for the purpose of earning income from a business or property (other than money used by the taxpayer for the purpose of acquiring property the income from which would be exempt),(ii.1)in the course of incurring indebtedness that is an amount payable for property acquired for the purpose of gaining or producing income therefrom or for the purpose of gaining or producing income from a business (other than property the income from which would be exempt or property that is an interest in a life insurance policy), or(ii.2)in the course of a rescheduling or restructuring of a debt obligation of the taxpayer or an assumption of a debt obligation by the taxpayer, where the debt obligation is(A)in respect of a borrowing described in subparagraph 20(1)(e)(ii), or(B)in respect of an amount payable described in subparagraph 20(1)(e)(ii.1),and in the case of a rescheduling or restructuring, the rescheduling or restructuring, as the case may be, provides for the modification of the terms or conditions of the debt obligation or the conversion or substitution of the debt obligation to or with a share or another debt obligation,(including a commission, fee, or other amount paid or payable for or on account of services rendered by a person as a salesperson, agent or dealer in securities in the course of the issuance, sale or borrowing) that is the lesser of(iii)that proportion of 20% of the expense that the number of days in the year is of 365 and(iv)the amount, if any, by which the expense exceeds the total of all amounts deductible by the taxpayer in respect of the expense in computing the taxpayer’s income for a preceding taxation year,and for the purposes of this paragraph,(iv.1)excluded amountmeans(A)an amount paid or payable as or on account of the principal amount of a debt obligation or interest in respect of a debt obligation,(B)an amount that is contingent or dependent on the use of, or production from, property, or(C)an amount that is computed by reference to revenue, profit, cash flow, commodity price or any other similar criterion or by reference to dividends paid or payable to shareholders of any class of shares of the capital stock of a corporation,(v)where in a taxation year all debt obligations in respect of a borrowing described in subparagraph 20(1)(e)(ii) or in respect of indebtedness described in subparagraph 20(1)(e)(ii.1) are settled or extinguished (otherwise than in a transaction made as part of a series of borrowings or other transactions and repayments), by the taxpayer for consideration that does not include any unit, interest, share or debt obligation of the taxpayer or any person with whom the taxpayer does not deal at arm’s length or any partnership or trust of which the taxpayer or any person with whom the taxpayer does not deal at arm’s length is a member or beneficiary, this paragraph shall be read without reference to the words “the lesser of” and to subparagraph 20(1)(e)(iii), and(vi)where a partnership has ceased to exist at any particular time in a fiscal period of the partnership,(A)no amount may be deducted by the partnership under this paragraph in computing its income for the period, and(B)there may be deducted for a taxation year ending at or after that time by any person or partnership that was a member of the partnership immediately before that time, that proportion of the amount that would, but for this subparagraph, have been deductible under this paragraph by the partnership in the fiscal period ending in the year had it continued to exist and had the partnership interest not been redeemed, acquired or cancelled, that the fair market value of the member’s interest in the partnership immediately before that time is of the fair market value of all the interests in the partnership immediately before that time;Marginal note:Annual fees, etc.(e.1)an amount payable by the taxpayer (other than a payment that is contingent or dependent on the use of, or production from, property or is computed by reference to revenue, profit, cash flow, commodity price or any other similar criterion or by reference to dividends paid or payable to shareholders of any class of shares of the capital stock of a corporation) as a standby charge, guarantee fee, registrar fee, transfer agent fee, filing fee, service fee or any similar fee, that can reasonably be considered to relate solely to the year and that is incurred by the taxpayer(i)for the purpose of borrowing money to be used by the taxpayer for the purpose of earning income from a business or property (other than borrowed money used by the taxpayer for the purpose of acquiring property the income from which would be exempt income),(ii)in the course of incurring indebtedness that is an amount payable for property acquired for the purpose of gaining or producing income therefrom or for the purpose of gaining or producing income from a business (other than property the income from which would be exempt or property that is an interest in a life insurance policy), or(iii)for the purpose of rescheduling or restructuring a debt obligation of the taxpayer or an assumption of a debt obligation by the taxpayer, where the debt obligation is(A)in respect of a borrowing described in subparagraph 20(1)(e.1)(i), or(B)in respect of an amount payable described in subparagraph 20(1)(e.1)(ii),and in the case of a rescheduling or restructuring, the rescheduling or restructuring, as the case may be, provides for the modification of the terms or conditions of the debt obligation or the conversion or substitution of the debt obligation to or with a share or another debt obligation.Marginal note:Premiums on life insurance — collateral(e.2)the least of the following amounts in respect of a life insurance policy (other than an annuity contract or LIA policy):(i)the premiums payable by the taxpayer under the policy in respect of the year, if(A)an interest in the policy is assigned to a restricted financial institution in the course of a borrowing from the institution,(B)the interest payable in respect of the borrowing is or would, but for subsections 18(2) and 18(3.1) and sections 21 and 28, be deductible in computing the taxpayer’s income for the year, and(C)the assignment referred to in clause 20(1)(e.2)(i)(A) is required by the institution as collateral for the borrowing(ii)the net cost of pure insurance in respect of the year (other than in respect of a period after 2013 during which the policy is a 10/8 policy), as determined in accordance with the regulations, in respect of the interest in the policy referred to in clause (i)(A), and(iii)the portion, of the lesser of the amounts determined under subparagraphs (i) and (ii) in respect of the policy, that can reasonably be considered to relate to the amount owing from time to time during the year by the taxpayer to the institution under the borrowing;Marginal note:Discount on certain obligations(f)an amount paid in the year in satisfaction of the principal amount of any bond, debenture, bill, note, mortgage, hypothecary claim or similar obligation issued by the taxpayer after June 18, 1971 on which interest was stipulated to be payable, to the extent that the amount so paid does not exceed,(i)in any case where the obligation was issued for an amount not less than 97% of its principal amount, and the yield from the obligation, expressed in terms of an annual rate on the amount for which the obligation was issued (which annual rate shall, if the terms of the obligation or any agreement relating thereto conferred on its holder a right to demand payment of the principal amount of the obligation or the amount outstanding as or on account of its principal amount, as the case may be, before the maturity of the obligation, be calculated on the basis of the yield that produces the highest annual rate obtainable either on the maturity of the obligation or conditional on the exercise of any such right) does not exceed 4/3 of the interest stipulated to be payable on the obligation, expressed in terms of an annual rate on(A)the principal amount of the obligation, if no amount is payable on account of the principal amount before the maturity of the obligation, or(B)the amount outstanding from time to time as or on account of the principal amount of the obligation, in any other case,the amount by which the lesser of the principal amount of the obligation and all amounts paid in the year or in any preceding year in satisfaction of its principal amount exceeds the amount for which the obligation was issued, and(ii)in any other case, 1/2 of the lesser of the amount so paid and the amount by which the lesser of the principal amount of the obligation and all amounts paid in the year or in any preceding taxation year in satisfaction of its principal amount exceeds the amount for which the obligation was issued;Marginal note:Share transfer and other fees(g)where the taxpayer is a corporation,(i)an amount payable in the year as a fee for services rendered by a person as a registrar of or agent for the transfer of shares of the capital stock of the taxpayer or as an agent for the remittance to shareholders of the taxpayer of dividends declared by it,(ii)an amount payable in the year as a fee to a stock exchange for the listing of shares of the capital stock of the taxpayer, and(iii)an expense incurred in the year in the course of printing and issuing a financial report to shareholders of the taxpayer or to any other person entitled by law to receive the report;Marginal note:Repayment of loan by shareholder(j)such part of any loan or indebtedness repaid by the taxpayer in the year as was by virtue of subsection 15(2) included in computing the taxpayer’s income for a preceding taxation year (except to the extent that the amount of the loan or indebtedness was deductible from the taxpayer’s income for the purpose of computing the taxpayer’s taxable income for that preceding taxation year), if it is established by subsequent events or otherwise that the repayment was not made as part of a series of loans or other transactions and repayments;Marginal note:Doubtful or impaired debts(l)a reserve determined as the total of(i)a reasonable amount in respect of doubtful debts (other than a debt to which subparagraph 20(1)(l)(ii) applies) that have been included in computing the taxpayer’s income for the year or a preceding taxation year, and(ii)where the taxpayer is a financial institution (as defined in subsection 142.2(1)) in the year or a taxpayer whose ordinary business includes the lending of money, an amount in respect of properties (other than mark-to-market properties, as defined in that subsection) that are(A)impaired loans or lending assets that are specified debt obligations (as defined in that subsection) of the taxpayer, or(B)impaired loans or lending assets that were made or acquired by the taxpayer in the ordinary course of the taxpayer’s business of insurance or the lending of moneyequal to the total of(C)the percentage (not exceeding 100%) that the taxpayer claims of the prescribed reserve amount for the taxpayer for the year, and(D)in respect of loans, lending assets or specified debt obligations that are impaired and for which an amount is not deductible for the year because of clause 20(1)(l)(ii)(C) (each of which in this clause is referred to as a “loan”), the taxpayer’s specified percentage for the year of the lesser of(I)the total of all amounts each of which is a reasonable amount as a reserve (other than any portion of which is in respect of a sectoral reserve) for a loan in respect of the amortized cost of the loan to the taxpayer at the end of the year, and(II)the amount determined by the formula0.9M - NwhereMis the amount that is the taxpayer’s reserve or allowance for impairment (other than any portion of the amount that is in respect of a sectoral reserve) for all loans that is determined for the year in accordance with generally accepted accounting principles, andNis the total of all amounts each of which is the specified reserve adjustment for a loan (other than an income bond, an income debenture, a small business bond or small business development bond) for the year or a preceding taxation year;Marginal note:Reserve for guarantees, etc.(l.1)a reserve in respect of credit risks under guarantees, indemnities, letters of credit or other credit facilities, bankers’ acceptances, interest rate or currency swaps, foreign exchange or other future or option contracts, interest rate protection agreements, risk participations and other similar instruments or commitments issued, made or assumed by a taxpayer who was an insurer or whose ordinary business included the lending of money in favour of persons with whom the taxpayer deals at arm’s length in the ordinary course of the taxpayer’s business of insurance or the lending of money, equal to the lesser of(i)a reasonable amount as a reserve for credit risk losses of the taxpayer expected to arise after the end of the year under or in respect of those instruments or commitments, and(ii)90% of the reserve for credit risk losses of the taxpayer expected to arise after the end of the year under or in respect of those instruments or commitments determined for the year in accordance with generally accepted accounting principles,or such lesser amount as the taxpayer may claim;Marginal note:Reserve in respect of certain goods and services(m)subject to subsection 20(6), where amounts described in paragraph 12(1)(a) have been included in computing the taxpayer’s income from a business for the year or a previous year, a reasonable amount as a reserve in respect of(i)goods that it is reasonably anticipated will have to be delivered after the end of the year,(ii)services that it is reasonably anticipated will have to be rendered after the end of the year,(iii)periods for which rent or other amounts for the possession or use of land or of chattels or movables have been paid in advance, or(iv)repayments under arrangements or understandings of the class described in subparagraph 12(1)(a)(ii) that it is reasonably anticipated will have to be made after the end of the year on the return or resale to the taxpayer of articles other than bottles;Marginal note:Manufacturer’s warranty reserve(m.1)where an amount described in paragraph 12(1)(a) has been included in computing the taxpayer’s income from a business for the year or a preceding taxation year, a reasonable amount as a reserve in respect of goods or services that it is reasonably anticipated will have to be delivered or rendered after the end of the year pursuant to an agreement for an extended warranty(i)entered into by the taxpayer with a person with whom the taxpayer was dealing at arm’s length, and(ii)under which the only obligation of the taxpayer is to provide those goods or services with respect to property manufactured by the taxpayer or by a corporation related to the taxpayer,not exceeding that portion of the amount paid or payable by the taxpayer to an insurer that carries on an insurance business in Canada to insure the taxpayer’s liability under the agreement in respect of an outlay or expense made or incurred after December 11, 1979 and in respect of the period after the end of the year;Marginal note:Repayment of amount previously included in income(m.2)a repayment in the year by the taxpayer of an amount required by paragraph 12(1)(a) to be included in computing the taxpayer’s income from a business for the year or a preceding taxation year;(m.3)the unamortized amount at the end of the year in respect of the amount that was received in excess of the principal amount of a bond (in this paragraph referred to as the “premium”) received by the issuer in the year, or a previous year, for issuing the bond (in this paragraph referred to as the “new bond”) if(i)the terms of the new bond are identical to the terms of bonds previously issued by the taxpayer (in this paragraph referred to as the “old bonds”), except for the date of issuance and total principal amount of the bonds,(ii)the old bonds were part of an issuance (in this paragraph referred to as the “original issuance”) of bonds by the taxpayer,(iii)the interest rate on the old bonds was reasonable at the time of the original issuance,(iv)the new bond is issued on the re-opening of the original issuance,(v)the amount of the premium at the time of issuance of the new bond is reasonable, and(vi)the amount of the premium has been included in the taxpayer’s income for the year or a previous taxation year;Marginal note:Reserve for unpaid amounts(n)if an amount included in computing the taxpayer’s income from the business for the year or for a preceding taxation year in respect of property sold in the course of the business is payable to the taxpayer after the end of the year and, except where the property is real or immovable property, all or part of the amount was, at the time of the sale, not due until at least two years after that time, a reasonable amount as a reserve in respect of any part of the amount that can reasonably be regarded as a portion of the profit from the sale;Marginal note:Reserve for quadrennial survey(o)such amount as may be prescribed as a reserve for expenses to be incurred by the taxpayer by reason of quadrennial or other special surveys required under theCanada Shipping Act, or the regulations under that Act, or under the rules of any society or association for the classification and registry of shipping approved by the Minister of Transport for the purposes of theCanada Shipping Act;Marginal note:Bad debts(p)the total of(i)all debts owing to the taxpayer that are established by the taxpayer to have become bad debts in the year and that have been included in computing the taxpayer’s income for the year or a preceding taxation year, and(ii)all amounts each of which is that part of the amortized cost to the taxpayer at the end of the year of a loan or lending asset (other than a mark-to-market property, as defined in subsection 142.2(1)) that is established in the year by the taxpayer to have become uncollectible and that,(A)where the taxpayer is an insurer or a taxpayer whose ordinary business includes the lending of money, was made or acquired in the ordinary course of the taxpayer’s business of insurance or the lending of money, or(B)where the taxpayer is a financial institution (as defined in subsection 142.2(1)) in the year, is a specified debt obligation (as defined in that subsection) of the taxpayer;Marginal note:Employer’s contributions to RPP or PRPP(q)such amount in respect of employer contributions to registered pension plans or pooled registered pension plans as is permitted under subsection 147.2(1) or 147.5(10);Marginal note:Employer’s contributions under retirement compensation arrangement(r)amounts paid by the taxpayer in the year as contributions under a retirement compensation arrangement in respect of services rendered by an employee or former employee of the taxpayer, other than where it is established, by subsequent events or otherwise, that the amounts were paid as part of a series of payments and refunds of contributions under the arrangement;Marginal note:Employer’s contributions under employee life and health trust(s)such amount in respect of employer contributions paid to a trustee under an employee life and health trust as is permitted by subsections 144.1(4) to (7);Marginal note:Patronage dividends(u)such amounts in respect of payments made by the taxpayer pursuant to allocations in proportion to patronage as are permitted by section 135;Marginal note:Mining taxes(v)such amount as is allowed by regulation in respect of taxes on income for the year from mining operations;(v.1)[Repealed, 2003, c. 28, s. 3]Marginal note:Employer’s contributions under profit sharing plan(w)an amount paid by the taxpayer to a trustee in trust for employees of the taxpayer or of a corporation with whom the taxpayer does not deal at arm’s length, under an employees profit sharing plan as permitted by section 144;Marginal note:Employer’s contributions under registered supplementary unemployment benefit plan(x)an amount paid by the taxpayer to a trustee under a registered supplementary unemployment benefit plan as permitted by section 145;Marginal note:Employer’s contributions under deferred profit sharing plan(y)an amount paid by the taxpayer to a trustee under a deferred profit sharing plan as permitted by subsection 147(8);Marginal note:Cancellation of lease(z)the proportion of an amount not otherwise deductible that was paid or that became payable by the taxpayer before the end of the year to a person for the cancellation of a lease of property of the taxpayer leased by the taxpayer to that person that(i)the number of days that remained in the term of the lease (including all renewal periods of the lease), not exceeding 40 years, immediately before its cancellation and that were in the yearis of(ii)the number of days that remained in the term of the lease (including all renewal periods of the lease), not exceeding 40 years, immediately before its cancellation,in any case where the property was owned at the end of the year by the taxpayer or by a person with whom the taxpayer was not dealing at arm’s length and no part of the amount was deductible by the taxpayer under paragraph 20(1)(z.1) in computing the taxpayer’s income for a preceding taxation year;Marginal note:Idem(z.1)an amount not otherwise deductible that was paid or that became payable by the taxpayer before the end of the year to a person for the cancellation of a lease of property of the taxpayer leased by the taxpayer to that person, in any case where(i)the property was not owned at the end of the year by the taxpayer or by a person with whom the taxpayer was not dealing at arm’s length, and(ii)no part of the amount was deductible by the taxpayer under this paragraph in computing the taxpayer’s income for any preceding taxation year,to the extent of the amount thereof (or in the case of capital property, 1/2 of the amount thereof) that was not deductible by the taxpayer under paragraph 20(1)(z) in computing the taxpayer’s income for any preceding taxation year;Marginal note:Landscaping of grounds(aa)an amount paid by the taxpayer in the year for the landscaping of grounds around a building or other structure of the taxpayer that is used by the taxpayer primarily for the purpose of gaining or producing income therefrom or from a business;Marginal note:Fees paid to investment counsel(bb)an amount, other than a commission, that(i)is paid by the taxpayer in the year to a person or partnership the principal business of which(A)is advising others as to the advisability of purchasing or selling specific shares or securities, or(B)includes the provision of services in respect of the administration or management of shares or securities, and(ii)is paid for(A)advice as to the advisability of purchasing or selling a specific share or security of the taxpayer, or(B)services in respect of the administration or management of shares or securities of the taxpayer;Marginal note:Expenses of representation(cc)an amount paid by the taxpayer in the year as or on account of expenses incurred by the taxpayer in making any representation relating to a business carried on by the taxpayer,(i)to the government of a country, province or state or to a municipal or public body performing a function of government in Canada, or(ii)to an agency of a government or of a municipal or public body referred to in subparagraph 20(1)(cc)(i) that had authority to make rules, regulations or by-laws relating to the business carried on by the taxpayer,including any representation for the purpose of obtaining a licence, permit, franchise or trademark relating to the business carried on by the taxpayer;Marginal note:Investigation of site(dd)an amount paid by the taxpayer in the year for investigating the suitability of a site for a building or other structure planned by the taxpayer for use in connection with a business carried on by the taxpayer;Marginal note:Utilities service connection(ee)an amount paid by the taxpayer in the year to a person (other than a person with whom the taxpayer was not dealing at arm’s length) for the purpose of making a service connection to the taxpayer’s place of business for the supply, by means of wires, pipes or conduits, of electricity, gas, telephone service, water or sewers supplied by that person, to the extent that the amount so paid was not paid(i)to acquire property of the taxpayer, or(ii)as consideration for the goods or services for the supply of which the service connection was undertaken or made;Marginal note:Payments by farmers(ff)an amount paid by the taxpayer in the year as a levy under theWestern Grain Stabilization Act, as a premium in respect of the gross revenue insurance program established under theFarm Income Protection Actor as an administration fee in respect of a net income stabilization account;(gg)[Repealed, 1994, c. 7, Sch