3 February 1994 External T.I. 5-923647

Although s. 56(4) could apply in some circumstances to a contractor transferring unapproved billings and unapproved holdbacks to a controlled corporation, RC generally will not apply this provision where the recipient of the transfer includes such amounts in its income as business income.

Holdbacks and unapproved billings of a contractor are eligible property in respect of which the elected amount can be $1.