12 December 1980 TI RCT 85-013

Before going to find that the contingent right to receive construction holdbacks was property that could be transferred on a rollover basis, RCT stated "we agree that the work in progress is inventory for purposes of subsection 85(1) if in fact it has been used in computing profit under section 9."

Construction holdbacks would be considered to be eligible property. The cost amount of the right would be calculated by eliminating the profit element from the face amount.