19 January 2009 Internal T.I. 2008-0305241I7 F - Impôt de la partie I.3 et PCGR -- summary under Subsection 181(3)

After indicating that where the amount of the paid-up capital for ITA purposes of shares issued on a s. 85(1) rollover transaction exceeded the amount recorded for those shares on the GAAP-basis financial statements, the latter amount should be used in computing capital under s. 181.2(3)(a), the Directorate stated that “the Agency has the ability to challenge the application of GAAP where it is of the opinion that GAAP has not been applied in a specific situation [citing Ford Credit].”