J.L. Guay Ltée v. MNR, 71 DTC 5423, [1971] CTC 686 (FCTD), aff'd 73 DTC 5374, [1973] CTC 506 (FCA), aff'd 75 DTC 5094, [1975] CTC 97 (SCC) -- summary under Incurring of Expense

A general building contractor in accordance with the terms of its contracts with its subcontractors withheld 10% of the amounts invoiced on a monthly basis to it by its subcontractors. The amounts withheld became due 35 days after a completion certificate was issued by the architect. Noel, A.C.J. stated that the practice of the taxpayer in deducting amounts which were not due until a subsequent taxation year was "contrary to the rule that an expenditure may only be deducted from income for the period in which it was made".