Imperial Oil Ltd. v. Canada; Inco Ltd. v. Canada, 2006 DTC 6639, 2006 SCC 46, [2006] 2 SCR 447 -- summary under Principal Amount

By services, 28 November, 2015

Before finding that the taxpayers were not entitled to recognize deductions under s. 20(1)(f)(ii) at the time they repaid U.S.-dollar denominated debentures following an appreciation in the U.S. dollar, LeBel J adressed (at para. 61) an argument that as the US dollar appreciated, the "principal amount" of the debentures increased:

[T]he arguments based on the use of the phrase "maximum amount" in the definition of "principal amount" fail because there is no indication that foreign currency conversions were in Parliament's contemplation when that section was drafted.

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