Folio reference to Mark Resources fails to acknowledge its obsolescence

In Folio S3-F6-C1, CRA indicates (perhaps somewhat contrary to TDL and Swirsky) that it is only in quite limited circumstances that it will consider investments in common shares to not be an eligible use of borrowed money. However, it then notes that in Mark Resources, where borrowed money was used to fund a cross-border investment in a U.S. Lossco, the interest deduction was denied because "the real purpose of the borrowing was to enable the Canadian corporation to absorb into its income the losses of its foreign subsidiary."

This reference is "puzzling." Leaving aside that the scheme would no longer work anyway, "Mark Resources is a clear outlier" as it departs from the s. 20(1)(c) (largely direct) use test as subsequently clarified by the Supreme Court of Canada (e.g., in Singleton).

Neal Armstrong. Summary of Nathan Boidman, Héléné Gagné, and Michael Kandev, "Interest Deductibility in Canada:  What's the Fuss?", Tax Notes International, July 13, 2015, p. 16 under s. 20(1)(c).