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The subject matter to be covered was divided into three parts: • Part One: Principles and methods • Part Two: Applications • Part Three: Specific subjects (e.g. permanent establishment) The report's revised Part One, containing the most important subject matter, was published in the summer of 1994 for comments by members of the public; the final version was published in July of 1995. ... There has been no radical change in recognition and classification of the various methods — the superiority of methods based on transaction values is reaffirmed. ...

Alternatively, paragraph 12(1)(b) of the Act could be invoked, as specified in section 5 of Interpretation Bulletin IT-170R: "... it is the Department's view that the sale price of any property sold is brought into account for income tax purposes when a vendor has an absolute but not necessarily immediate right to be paid. ...