Regarding a question on the holding of surplus funds by a non-profit organization (“NPO”), CRA stated:
The holding of surplus funds is generally an indicator of activities carried on for the purpose of generating profits, but this fact alone will not prevent an NPO from coming within paragraph 149(1)(l) if, for example, the purpose of holding the surplus funds is to fund a specific project of a capital nature. In this context, an NPO could accumulate contributions from its members and earn investment income on those amounts even though the income generated by those investments is anticipated. However, where the purpose of the funds accumulated and invested by the association is to make a profit and not to fund a specific project of a capital nature, the association would not satisfy the conditions in paragraph 149(1)(l).
CRA went on to note that taxable capital gains from a disposition were exempt subject to s. 149(5).