Is a corporation in the business of exploring, developing and producing hydrocarbons at various locations in Canada carrying on a single business such that the acquisition or disposition of a property is not the acquisition or disposition of a separate business for purposes of Reg. 1101(1)? CRA responded:
[T]he determination of whether a person is carrying on a single business or multiple separate businesses is fact driven and a general answer would not be appropriate.
We do acknowledge that, in the oil and gas industry, it is common for businesses to acquire properties and dispose of non-core properties on a continual basis. Generally, the acquisitions and dispositions during the normal course of business would not be considered acquisitions or dispositions of separate businesses.