Originally published in Tax Notes International, this article examines the conclusions reached by both the Tax Court of Canada denying an interest deduction and by the Federal Court of Appeal subsequently allowing the deduction in an effort to identify a more unified theory on the proper approach.

This article was written with the collaboration of Dov Whitman.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.