Manufacturers Life Insurance Co. v. The Queen, 2000 DTC 1600 (TCC) -- summary under Subsection 181.3(1)

In the financial statements of the taxpayer (a life insurance company) that were prepared in accordance with the OSFI rules, gains or losses realized from the disposition of investments together (in some cases) with unrealized gains and losses were amortized as an addition to (or deduction from) income over time on a systematic basis, with the unamortized gain (or loss) being subtracted (or added) to the carrying value of the taxpayer's investments shown on its balance sheet. O'Connor TCJ. found that because the taxpayer thus did not treat the unamortized gains as "surplus" or a "reserve" in its balance sheet, they were not included in capital under s. 181.3(3)(b)(ii) or s. 181.3(1)(c)(ii)(B)(I).