18 October 2011 External T.I. 2011-0394041E5 F - Fiducie personnelle- revenu brut -- summary under Section 3

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] capital gain is not income from a source. … [A]ny capital gain realized by an individual referred to in paragraph 110.6(1.3)(a) that is not included in computing that individual's gross revenue should also not be included in the calculation of that individual's income from all other sources.

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