A corporation with fewer than six full-time employees leases six trailers to contractors in order for them to lodge their employees, provides the trailers on a furnished basis, including dishes, bedding and a laundry room. Trailer rental also includes various services such as utilities, snow removal, grounds maintenance, supply and washing of bedding, supply of cleaning products and other maintenance – and also provides housekeeping services two to three times a week for each trailer.
After assuming that the rented trailers were real property, CRA stated:
[T]he extent to which basic services and additional services are provided to tenants ... will determine whether the activity generates income from a business. … [W]e believe that the income generated by the trailer rental corporation is active business income.