Before finding that s. 127(1)(av) of the 1948 Act did not apply to require the deduction of interest on general corporate borrowings of the taxpayer from its interest income on a loan to a U.S.subsidiary (so as to deny a foreign tax credit for US withholding tax levied on such interest income), Locke J. stated (p. 1233) that the provision was intended:
"to prevent a taxpayer who might be engaged in two separate businesses not related to each other by reason of their nature from taking into account losses or expenses incurred in one in computing the taxable income of the other."