5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F - entreprise exploitée activement – revenu de location -- summary under Specified Investment Business

In the course of a general discussion as to whether a Canadian-controlled private corporation with rental properties carried on an active business, CRA stated (before referring to the more-than-five full time employee test):

A "specified investment business" is essentially a business, including a business of leasing real or immovable property, the principal purpose of which is to derive income from property, including rents. As stated in paragraph 12 of Interpretation Bulletin IT 73R6, the term "principal purpose" is not a defined term in the Act for the purposes of the definition of "specified investment business" in subsection 125(7), but it is considered to be the main or chief objective for which the business is carried on. In order to identify the "main objective", therefore, an analysis of all factors related to the process needed to earn income is required.

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