Interprovincial Pipe Line Company v. Minister of National Revenue, 68 DTC 5093, [1968] CTC 156, [1968] SCR 498 -- summary under Subsection 4(3)

The enactment of s. 139(1b) (now s. 4(3)) required the taxpayer to net related interest expense against interest income receivable by it from its U.S. subsidiary for purposes of computing the foreign tax credit available to it with respect to U.S. withholding taxes exigible on the interest income receivable by it from the U.S. subsidiary.