RC's policy that interest is deductible to the extent that the borrowing is not in excess of the paid-up capital reduction which the borrowing funded is consistent with the Trans-Prairie decision. RC further noted that in applying this policy:
[T]he reference to "paid-up capital" therein was meant to refer to the accounting concept of "capital" except in circumstances in which the capital has been increased in non-arm's length transactions such as may occur in an amalgamation of related corporations. In such cases in which there is an increase to the capital because of a non-arm's length transaction (other than a direct subscription for shares or capital contribution), the concept of capital for the purposes of measuring a the maximum borrowing permissable should be limited to the corporate capital as would be determined in the absence of such an increase.