The appellant appealed a reassessment disallowing the deduction of $26,510,522 in non-capital losses for its 2014 taxation year.
The losses arose from a payment made by a subsidiary to a related corporation to assume lease obligations for discontinued theatres prior to the appellant acquiring the subsidiary.
The Tax Court of Canada allowed the appeal, finding that the payment was a deductible current expense incurred to terminate unprofitable business operations, not a capital outlay or negative proceeds of disposition.
