Industries Perron Inc. (anciennement 3654419 Canada Inc.) v. The Queen, 2012 DTC 1072 [at at 2836], 2011 TCC 433, aff'd 2013 FCA 176 -- summary under Paragraph 18(1)(e)

Angers J. denied the taxpayer's deduction of a reserve it made in respect of preliminary anti-dumping rulings against it from the International Trade Commission ("ITC") and the U.S. Department of Commerce ("DOC") respecting the importing of lumber, notwithstanding that the taxpayer was required to post cash deposits as security for its potential obligation. The anti-dumping duties were not deductible by virtue of s. 18(1)(a) and (e) because the taxpayers did not have a duty to pay until the ITC and DOC made their final determinations (although it did have a duty to either pay or create a bond before customs would allow the importing), nor was the amount of the payment certain until then.