Demeterio v. The Queen, 2011 DTC 1148 [at at 788], 2011 TCC 192 -- summary under Paragraph 12(1)(a)

The taxpayer earned commissions on his sale of life insurance policies, which he had to repay if the policies were cancelled within two years. Woods J. dismissed the taxpayer's submission that the commissions should only be included in income after two years. The wording of s. 12(1)(a)(i) clearly includes such unearned amounts in the year of receipt. (Woods J. noted that, ordinarily, such income inclusions can be offset under s. 20(1)(m), but that the deduction was not available to the taxpayer in this case because of s. 32.)