18 October 2011 External T.I. 2011-0394041E5 F - Fiducie personnelle- revenu brut -- summary under Gross Revenue

S. 110.6(1.3)(b)(i)(A) referenced a basis for a property being considered to be being used in the course of carrying on a farming business in Canada based inter alia on a two-year test of the “gross revenue from farming” exceeding the income of the operator from all other sources during that period. CRA stated:

[A]n individual referred to in paragraph 110.6(1.3)(a) must not include in computing the individual’s gross revenue - under clause 110.6(1.3)(b)(i)(A) - the capital gains the individual realized. Indeed, the term "gross revenue" is defined in subsection 248(1) and excludes amounts received as capital.

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