25 March 1999 Internal T.I. 9828577 - PART I.3/RESERVES,ADVANCES&SURPLUS -- summary under Timing

upfront fees received on interest/currency swaps likely were includible in income under s. 9 (so that no reserve under s. 20(1)(m) was available) on the basis that that had been legally earned, as the taxpayer was not required to provide any further services or deliver any goods.