In finding that the taxpayer was entitled to deduct the full amount of the interest coupon payments made by it on a periodic basis to a Belgian bank, Mogan, D.J. noted that although when the Belgian bank looked at the quarterly interest payments, it saw "43/50 of each amount as a recovery of capital and 7/50 of each amount as interest," this represented the wrong point of view. From the taxpayer's perspective, each interest coupon payment represented the payment in full of interest, given that $140,000,000 of principal remained outstanding after each interest coupon payment.
Note
rev'd on other grounds 2010 DTC 6844, 2010 FCA 124
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stripped interest coupons on principal still owing were not blended payments
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"field_legacy_header": "<strong><em>Lehigh Cement Ltd. v. The Queen</em></strong>, 2009 DTC 776, 2009 TCC 237, rev'd on other grounds 2010 DTC 6844, 2010 FCA 124 <strong>[stripped interest coupons on principal still owing were not blended payments]</strong>",
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