Where a taxpayer makes In-App sales of life or experience points to gamers, is there an inclusion under s. 12(1)(a) and a deduction under s. 20(1)(m)? CRA responded (TaxInterpretations translation):
]T]he taxpayer would cash the amount immediately and the client would receive the supplementary life or experience points from the time the payment was made. The taxpayer would have no further obligation respecting this sale. Having said that, it could be that the client does not use the points immediately or that they are utilized over the course of the current game. However, that does not cause the product not to have been delivered or the service not to have been rendered. Therefore…if there is need to determine a reserve for the amounts received, it would be nil.