CRA confirms acceptance of Singleton-style mechanical tracing approach

CRA has confirmed that the interest-tracing approach relied upon in Lipson would have "worked" but for the application of GAAR to the transactions on the basis that there was an abuse of the income attribution rules.

Neal Armstrong.  Summary of 27 February 2013 T.I. 2013-0477601E5 under s. 20(1)(c).