Ford Credit Canada Limited v. The Queen, 2006 DTC 3424, 2006 TCC 441 -- summary under Subsection 181(3)

By services, 28 November, 2015

Retractable preferred shares in the capital of the taxpayer (a financial institution) were not included in its capital under s. 181.3(3)(a) given that in its balance sheet prepared in accordance with GAAP those preferred shares were treated as debt.

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