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. Corporation A deducts as expense an estimate of the rent and labour costs that it could eventually incur to meet its obligations to its customers. The Directorate stated:
[T]he terms of paragraphs 18(1)(a) and (e) generally do not allow for any deduction or allowance to account for obligations that Corporation A may eventually incur.