Upper Lakes Shipping Ltd. v. Minister of National Revenue, 98 DTC 6264, [1998] 3 CTC 281 (Ont CA) -- summary under Subsection 181.2(3)

Given that generally accepted accounting principles require that a government grant relating to a capital asset be included in retained earnings or "earned surplus" only as the assets are used in the operation of the business, the taxpayer was permitted to follow the same approach in computing its paid-up capital for Ontario capital tax purposes.