2004 APFF Roundtable Q. 8, 2004-008675 -- summary under Subsection 181(4)

In indicating that s. 181(4) would not provide relief where an insurance company issued $1 million of shares in order to acquire a building for $1 million (thereby resulting in an increase in its paid-up capital of $2 million, not $1 million, the Directorate stated that "subsection 181(4) ITA is for situations where the same balance sheet item is included pursuant to two or more Part I.3 ITA provisions which is not the case in the situation described."