AUG 28 1990
HALIFAX DISTRICT OFFICE Rick Mundell W.J. O'Hearon (613) 957-2139
901502
24(1) 19(1)
This is in reply to your letter of July 6, 1990, wherein you requested our views with respect to whether 24(1)
Our Comments
24(1)
In this connection, we note that "active business
carried on by a corporation" means any business carried on by the
corporation other than a specified investment business or a
personal services business.With respect to the definition of a specified investment business, as you have noted, subparagraphs 125(7)(e)(i) and (ii) of the Act set out the conditions which must be met to be excluded from that definition. Thus, where a corporation carries on a business in a taxation year the principal purpose of which is to derive income from property and neither of the aforementioned conditions are met, it is our view that the corporation would be considered a specified investment business.
In the particular example at hand the
24(1)In this regard we suggest that you contact Mr. Walter Szyc of that office to whom we have forwarded a copy of this memo.
We trust our comments will prove helpful.
Yours truly,
for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch
c.c. Audit Applications Division