In finding that construction holdbacks by a subcontractor did not become receivable until their release was approved by the architect or engineer, the Directorate stated:
A right to receive an amount exists where the vendor has an absolute, but not necessarily immediate, right to be paid. This absolute right exists when all the suspensive conditions of a contract are satisfied. A suspensive condition is an event (beyond the vendor's control) that suspends the performance of the contract (such as the right to be paid in the case of a holdback) until the condition is satisfied or waived and which could void the contract from the outset if the condition is not satisfied or waived. We understand that holdbacks are refundable only when all work has been satisfactorily completed. Consequently, we are of the view that such holdbacks will constitute amounts receivable when a client's architect or engineer has confirmed that the work performed by the Taxpayer is satisfactory.