8 December 2010 External T.I. 2010-0375921E5 - Subsection 20(24) -- summary under Subparagraph 12(1)(x)(iv)

Where no s. 20(24) election was made in the situation where the vendor of a business has paid a purchaser to assume its deferred revenue obligations, the vendor is not entitled to the deduction under s. 20(24), but the payment nonetheless will be included in the purchaser's income under s. 9 or 12(1)(x).