The taxpayer borrowed money from a bank in order to make interest-free advances to its wholly-owned non-resident subsidiary, which subsequently became insolvent. The Directorate stated:
[T[he taxpayer could deduct the interest owed to the Bank if it can demonstrate that, at the time it made the advance to the subsidiary, it had an expectation of income from the shares. If it can so demonstrate, the interest will be deductible pursuant to paragraph 20(1)(c). In addition, the provisions of subsection 20.1(1) may be applicable if there is a disposition of the shares.