Neal Armstrong reports that the Quebec Court of Appeal, in Emballages Starflex Inc. v Agence du revenu du Québec, 2016 QCCA 1856, has held that a corporation cannot deduct a gift to a charity as a business or promotional expense. The Court of Appeal cited Symes v Canada, [1993] 4 SCR 695, 1993 CanLII 55, as authority for the proposition that an amount should not be deductible under general principles as a business expense “in the face of a specific and complete regime” (here, presumably, for the deduction of charitable gifts).
