Any significant capital project will involve at least two stages: (1) work undertaken to examine the feasibility of the project, with a view to assisting directors or other corporate officers in determining whether or notto formally approve and actually implement the project (Oversight Expenses); and (2) actual implementation and execution of the project, if formally approved (Execution Costs).  In Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172, the Tax Court of Canada (TCC) usefully reaffirmed the judicial principle in Canada that Oversight Expenses are fully deductible under s. 9(1), notwithstanding that they relate to a potential capital project and whether or not the capital project is ultimately implemented (see paragraphs 80 to 89; Bowater Power Co. Ltd. v. MNR, 71 DTC 5469; Wacky Wheatley’s TV & Stereo Ltd. v. MNR, 87 DTC 576; and IT-475, paragraph 5).  The TCC noted that Oversight Expenses are important in “the modern corporate world” (see paragraph 87) and are fully deductible because they relate to the management of a corporation’s (ordinary day-to-day) income-earning process (see paragraph 88).  Evidence should be preserved in the course of any particular capital project, as it may be required prove on which side of the line a particular cost falls (see paragraphs 57 and 88).  The TCC also helpfully confirmed that a parent company in a corporate group (Parent) can hold shares of subsidiaries on capital account in the course of the Parent’s own business (see paragraphs 178 and 180).