Sudbrack v. The Queen, 2000 DTC 2521 (TCC) -- summary under Self-Contained Domestic Establishment

By services, 28 November, 2015

The taxpayer and his spouse operated a tourist guest home and used 15% of the area of the home as a private living area ("consisting of a bedroom, living area, bathroom and two bedrooms in an attic for their daughters"). In finding that this private living area was itself a self-contained domestic establishment, rather than the whole of the home constituting such an establishment, Bowman A.C.J. found (p. 2524) that the living quarters were essentially a separate apartment within the inn, and that finding was "more consonant with what subsection 18(12) is seeking to achieve".

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