Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them in a trust account, and also, in their year end balance sheets, reported the current balances in the trust accounts as assets and also as liabilities, labelled as "customer deposits and deferred revenue". CRA stated:
[A]mounts received by a travel agent from customers and shown as liabilities must be included in capital if they are covered by the provisions of subsection 181.2(3) even if they are required to be placed in trust under the Quebec or Ontario legislation described above.