Destacamento v. The Queen, 2009 DTC 806, 2009 TCC 242 (Informal Procedure) -- summary under Timing

The taxpayers, who were life insurance salesmen, received advance commissions when they sold a policy but with a requirement to pay back a portion of the commissions if the customer cancelled the policy within two years. In finding that the full amount of the advance commissions were income when received, V.A. Miller, J. noted that there is no interest charged on the advance commissions and that the taxpayers were not subject to any restrictions on the right to dispose of the amounts so received by them.