The taxpayer ran, along with its subsidiaries, a lumber and paper goods business with annual sales of approximately $2.5 billion. In response to the group's accounts receivable being denominated in foreign currencies, the taxpayer began trading options. The trading quickly expanded, with one currency trader and three bond and security traders. The team's stated objective was to mirror, on a smaller scale, the "same sort of structure" as the trading flow of TD Bank.
In the course of finding that the taxpayer could treat its options as inventory (and hence claim losses in the year in question based on a decline in the value of its portfolio), Rip J found that the taxpayer's trading activities constituted a business. He noted, for example, the scale of operations (it was the third- or fourth-largest currency options trader in Quebec), and its conduct generally reflected a business enterprise entirely separate from its manufacturing business (para. 38).
See summary under s. 9 –timing.