14 March 2011 External T.I. 2010-0382091E5 F - Revenu d'entreprise exploitée activement -- summary under Nature of Income

A corporation (the "Taxpayer") provides fully furnished housing units (bedding, dishes, television and cable) to victims of disasters such as from fire or flood for short-term rental, and also provides complete cleaning services. In addressing whether the Taxpayer derives its income from property or a business, CRA stated (without referring to the specified investment business definition):

[I]ncome generated by the Taxpayer's activities appears to be more like income from property. Indeed, the services offered by the Taxpayer do not seem as exhaustive as those provided by a taxpayer operating a motel or a hotel, the latter activities representing activities that give rise to income from a business.

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d7 import status
Drupal 7 entity type
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Drupal 7 entity ID
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