Air Canada v. Min. of Fin. for B.C., [1981] 2 WWR 97 (BCCA) -- summary under Paragraph (a)

Certificates of deposit, bearer deposit notes, swap deposit confirmations and bankers' acceptances were held to be "loans and advances to other corporations" rather than "cash on deposit with ... a savings bank" within the meaning of the definition of taxable paid-up capital in the Corporation Tax Act (B.C.). Carrothers, J.A. stated that one must contrast the characteristics of the above bank paper "with the distinctively different characteristics of a cash deposit, which has the attributes of ready availability, use in exchange (orders to pay can be made upon it in the form of a direct order or sometimes a cheque), debtor-creditor relationship in regard to simple debt, and, unlike bank paper, no documentary indicia of the debt other than a ledger or computer entry and perhaps a simple receipt." [C.R.: 212(1)(b)(iii)(D)]