Peach – Federal Court of Appeal finds that s. 67 cannot be applied on a global basis

Trudel JA noted that s. 67 should be applied on an expense-by-expense basis to determine what is the reduction in each expense which would render it reasonable. Accordingly, the Tax Court Judge had erred in instead considering whether, globally, the taxpayer’s business expenses were reasonable.

Neal Armstrong. Summary of Peach v. The Queen, 2016 FCA 173 under s. 67.