Scott v. MNR, 89 DTC 218, [1989] 1 CTC 2305 (TCC) -- summary under Paragraph 20(1)(c)

The taxpayer was not entitled to deduct interest on borrowed money which he had on-lent on a non-interest bearing basis to two corporations of which he was a shareholder, which corporations used the funds to generate business income. In addition, the policy in IT-445 did not apply because the taxpayer enjoyed a distinct tax advantage in the form of using the interest expense to offset other sources of income.