Corporation A, which is involved in the distribution, warehousing, handling, and packaging of goods, invoices and receives revenue currently for such goods processing services to be rendered in the following six to 12 months. In discussing the application of ss. 9 and 12(1)(a), and before going on to discuss the s. 20(1)(m) reserve, the Directorate stated:
The goods processing services to be performed after the end of the year appear to us to be of sufficient importance that the prepayments cannot be included in computing income from a business under subsection 9(1).
On the other hand, since Corporation A received advance payments in respect of goods processing services to be performed after the end of the taxation year, these amounts come within paragraph 12(1)(a) … .