Tax appeal concerning the proper timing of deductions for tenant inducement payments made by a commercial real estate developer in a highly competitive leasing market.
The Court held that profit under the Income Tax Act is determined by any method consistent with the Act, case law, and well-accepted business principles that yields an accurate picture of income for the year.
The matching principle was not a rule of law and could not be imposed automatically where the payments generated both immediate and future benefits.
Because the taxpayer's method provided an accurate picture of income and the Minister failed to show that amortization was more accurate, the appeal was allowed and the full deduction in the year incurred was restored.
