The taxpayer, which had two employees including its shareholder, carried on a storage unit rental business.
Before referring to the "principal purpose" test and stating (at para. 26) that "whether we substitute ‘main' or ‘chief' or primary' or ‘51%', it comes down to an objective determination of what the payor was paying for," C Miller J noted that the taxpayer provided additional services free of charge, mostly respecting assistance in moving items into or out of storage, and stated (at para. 20) that he was not satisfied that "they are indeed core to what customers were paying for." Respecting a submission (at para. 27) that there was no difference with "the motel customer paying for a room", he indicated that even a small motel would be expected to provide additional services, such as utilities (e.g. phone, electricity, Internet), daily room cleaning, linens, parking and amenities, and then stated (at paras. 28-29):
Every hotel customer has an expectation of a bundle of hotel services in addition to the use of a furnished room. I have not been convinced that every customer seeking storage space has any greater expectation than the space itself and not an expectation of a bundle of services equivalent to hotel accommodation.
There is a tipping point where the provision of services overcomes the provision of property. … [A] few services to a few customers does not change the inherent nature of income from property.
The taxpayer was carrying on a specified investment business.