Holzhey v. The Queen, 2008 DTC 2607, 2007 TCC 247 -- summary under Paragraph 12(1)(c)

The deemed disposition by the taxpayer, as a result of his ceasing to be a resident of Canada, of a loan made by him to a non-resident corporation on which there was accrued but unpaid interest resulted in him being thereby deemed to receive an amount "in lieu of" the payment of interest. In the Transocean case, amounts paid in respect of the anticipatory breach of a rental agreement were found to be a reasonable substitute for rent payable under the agreement; and similarly, here "the deemed proceeds were a reasonable substitute for the accrued interest". (para. 37)