Canadian Marconi v. R., 86 DTC 6526, [1986] 2 CTC 465, [1986] 2 SCR 522 -- summary under Canadian Manufacturing and Processing Profits

Interest, which an electronic equipment manufacturer received from short term loans and certificates of deposit which it had acquired out of the proceeds of sale of a broadcasting station, was held to be "income ... from an active business carried on in Canada." The manufacturer has a specific "investment business" object, and there is a rebuttable presumption that income earned by a corporation in the exercise of its duly authorized objects is income from a business. In addition "the extensive activities of the [taxpayer's] employees in purchasing short-term investments, the large number and high value of those transactions, the high proportion which the interest earned bore to the total income of the company and the high proportion which the total value of the investments bore to the total value of [the taxpayer's] assets" reinforced the character of the interest as business income.