Foreign Exchange

FX gains or losses of money-lender on its borrowings (and receivables) were on income account, eligible for accrual treatment

surrogatum principle applied to FX hedging termination payment

CGE established that accrued loss on FX forward contract is not a contingent liability

short-term debt securities were inventory because they were the raw material for generating swap income

loan repayments on capital account

gain on settlement of yen overdraft incurred to cover operating expenses was an income gain

settlement, years' later, of borrowing to fund inventory purchases, generated a taxable FX gain

general corporate borrowing on income account