Canadian Pacific Ltd. v. The Queen, docket 95-3534-IT-G (TCC) -- summary under Paragraph 20(1)(c)

Although he would have decided the appeal on a different basis if not bound by authority, Bonner TCJ. applied the finding in the Shell Canada case to a similar set of facts in concluding that the true interest payable by the taxpayer should be an amount that represented an amortization of the gain to be realized under the forward currency purchase, and on the basis that the reasonableness limitation in s. 20(1)(c) was to be measured by reference to a reasonable rate of interest for the borrower to pay and not the rate which was reasonable for a lender to charge.