CCLI (1994) Inc. v. The Queen, 2006 DTC 2695, 2006 TCC 240 -- summary under Foreign Exchange

The taxpayer was found to have incurred foreign exchange losses on U.S.-dollar borrowing that were used by it to purchase railcars and aircraft for leasing purposes on capital account. Although the taxpayer carried on a financing business and although in Avco Financial Services Ltd. v. Federal Commissioner of Taxation (1982), 13 ATR 63 (Aust. (AC) hire purchase agreements were treated as being in the same category as money lending activities, in that case no borrowings were for the purpose of specific lending transactions whereas here, at the time the taxpayer borrowed the money, the borrowed money was earmarked to buy specific railcars or aircraft.