A holding corporation earned deemed active business income under s. 129(6) from renting a building to an associated corporation for two years, and thereafter earned property income from renting the property to a non-associated corporation – and then disposed of the property, thereby realizing recapture of depreciation. Respecting a proposal that such recapture be prorated between active business income and property income based on the respective periods of time that the property generated the two types of income, the Directorate stated:
In the context of the situation under review, the position you propose, which is to treat a portion of the recaptured depreciation as income from an active business and another portion as property income, appears reasonable to us although there is no provision in the Act expressly supporting this conclusion.