I think one key phrase is; "directed mainly to a Canadian market". If you're buying global or mainly US traffic traffic you're ok. The only way you would not be able to deduct is if you were buying Canadian traffic from a non-Canadian (eg. Google) source.
And "issue of a non-Canadian newspaper or periodical". I don't think anyone can make the arguement that a search engibe is a "newspaper" or "periodical".
I think that section of the tax act was meant to protect against "split-run" US magazines, that were quite popular with US publishers a number of years ago.
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AdultAdBroker - Buy and Sell Your Flat Rate Banners, Links, Tabs, Pops, Email Clicks and Members' Area Traffic - updated Sept 2025
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