When asked, how are the factors in IT-479R, para. 11, interpreted, CRA responded:
As stated in ¶12 of the Bulletin, none of the factors stated in ¶11 may be sufficient, on their own, to determine whether a taxpayer's activities are those of a business, but a combination of those factors may be sufficient. The fact that a taxpayer generates a given number of transactions annually is not, in and of itself, a determining factor. Similarly, the fact that a taxpayer reports a large loss in the first year in which the election is made is also not a determinative factor. However, these factors could be indicators of the presence of any of the factors mentioned in ¶11. The presence of a combination of these factors may lead to the conclusion that the taxpayer's activities are those of a business.