Regarding a question as to the timing of recognition of qualifying revenue, whose definition in s. 125.7)1) referred to the “inflow” of cash, receivables or other consideration arising in the course of the eligible entity’s ordinary activities in Canada, CRA stated:
Subsection 125.7(4) enacts that the qualifying revenue of an eligible entity is generally determined in accordance with its normal accounting practices. Normal accounting practices may vary from taxpayer to taxpayer. … [T]here are situations in respect of which our Directorate will not or cannot issue an advance income tax ruling (“ruling”). In situations involving an opinion on accounting or commercial principles, practices, or guidelines, we will not issue a ruling or a technical interpretation.