CRA has remitted to Finance the issue that deductions for ads by Canadian advertisers on foreign websites are not limited by the foreign broadcaster and periodical rules
After noting that the ss. 19 to 19.1 rules, which essentially deny a deduction for ads directed at the Canadian market on foreign broadcasting, newspaper and periodical outlets, “do not apply to the deductibility of advertising expenses on foreign Internet websites,” CRA stated:
The Department of Finance…is aware of this issue and of the CRA’s position.
Neal Armstrong. Summary of 20 June 2017 Ministerial Correspondence 2017-0697751M4 under s. 19.1(1).