Would intangible assets of an active business carried on by a corporation, such as goodwill, customer list, licenses, franchises and quotas, be “active assets” as defined in s. 125(7)? After referring to Ensite and IT-73R6, para. 6, CRA stated:
In our view, where a business relies on such intangible assets to fulfill a requirement which had to be met in order to do business, are integral to the overall operations of the business, and selling or otherwise disposing of that property would have a “decidedly destabilizing” effect on the business operations, then it would be reasonable to conclude that those intangible assets were used in the active business.
Accordingly, such intangible assets could be active assets.