The taxpayers each owned 25% of the shares of a Canadian-controlled private corporation that leased manufactured homes on Indian-reserve lands that were leased to it. The corporation did not qualify as a small business corporation. In determining that the business of the corporation was a specified investment business, Sharlow, J.A. noted (at para. 26):
"The key question is whether the principal purpose of that business at that time was to derive income from property (such as rent). It is not relevant that [the corporation] carried on an active business before that time."