28 November 2010 CTF Roundtable, 2010-0386301C6 - NPO Carrying on Business for Profit -- summary under Paragraph 149(1)(l)

In response to a general inquiry as to when an NPO is carrying on a business for profit, CRA stated:

Paragraph 7 of Interpretation Bulletin IT-496R (note 3) provides a list of characteristics that the CRA will consider in making this determination. The court in BBM agreed that these were reasonable considerations for the purposes of applying the tax exemption. The characteristics considered include whether

  • there is a trade or business in the ordinary sense,
  • goods or services are restricted to members and their guests,
  • the business is operated on a profit basis rather than a cost-recovery basis, and
  • the business is operated in competition with taxable entities carrying on the same trade or business.
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Topic
Income Tax Act - s. 149(1)(l)
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Drupal 7 entity ID
324769
d7 import status
Drupal 7 entity type
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Drupal 7 entity ID
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