Gulfmark offshore N.S. Limited v. Canada, 2007 DTC 5563, 2007 FCA 302 -- summary under Article 7

Before the taxation year in question, the taxpayer, which was a U.K. company with a fleet of 27 supply vessels including a ship that was operated for 88 days in that year in the Nova Scotia offshore area, borrowed money from its parent company to construct new ships in addition to the refinancing of the taxpayer's outstanding debts. The taxpayer was unable to deduct any portion of the interest on the loan from its parent in the absence of more complete evidence on how that loan was used.