333.5. A taxpayer shall include, in computing the taxpayer’s income for a taxation year, the aggregate of all amounts each of which is an amount in respect of a restrictive covenant of the taxpayer that is received or receivable in the year by the taxpayer or by a taxpayer with whom the taxpayer does not deal at arm’s length, other than an amount that has been included in computing the taxpayer’s income under this section for a preceding taxation year or the taxpayer’s eligible corporation’s income under this section for the year or a preceding taxation year.
If the first paragraph applies to include, in computing a taxpayer’s income, an amount received or receivable by another taxpayer, the amount must not be included in computing the other taxpayer’s income.