Ford Credit Canada Limited v. The Queen, 2006 DTC 3424, 2006 TCC 441 -- summary under Accounting Principles

Before going on to find that s. 181(3) required retractable preferred shares in the capital of the taxpayer to be treated as debt for large corporation capital tax purposes, Bowman C.J. stated that even though the preferred shares were as a matter of economic substance similar to debt, in the absence of s 181(3), the accounting treatment of the preferred shares as debt would not be allowed to prevail over the legal meaning of the words equity and debt in the Act.