principal business

2 June 2006 External T.I. 2006-0174671E5 F - Frais de repas et de logement -- summary under Paragraph 8(1)(g)

In finding that employees of a company working in the field of pumping and transporting liquid waste and who typically were required to drive more than two hours to reach the customer site, received taxable benefits on being reimbursed for meals for every 12 hours of work, CRA stated:

Our understanding is that transport is a service ancillary to the other services of the business. … [T]he term transport business does not include a transportation service that is incidental, where the services offered are offered as part of a whole.

15 September 1992 T.I. (Tax Window, No. 24, p. 9, ¶2179) -- summary under Subsection 1100(26)

The expression "distribution or production" should be interpreted broadly and would include "transmission". Whether a corporation's principal business is transmission, is not based solely on its revenues and net income and entails consideration of such factors as income, gross revenue, operating cost, and expenses associated with each business; the capital employed in each business; and the time and effort expended by employees in respect of each business.

By services, 28 November, 2015

Indema Ltd. v. The Queen, 92 DTC 6244, [1992] 1 CTC 309 (FCTD) -- summary under Investment Business

The taxpayer was incorporated in 1972 in order to act as a distributor, but four years later its objects were extended and in 1978 it agreed to provide management and administrative services to two connected companies and in the taxation years in question it derived over 97% of its gross income as fees from those corporations. Jerome A.C.J. found that the taxpayer was not carrying on a "non-qualifying business" for purposes of former s.

By services, 28 November, 2015

Minister of National Revenue v. Consolidated Mogul Mines Limited, 68 DTC 5284, [1968] CTC 429, [1969] SCR 54 -- summary under Principal-Business Corporation

In its 1957 to 1960 taxation years, the taxpayer carried on exploration work on properties in which it had a direct interest. However, its chief task was the development and management of properties owned by other companies in which it usually had a share interest. It generally subscribed for shares in a corporation owning prospects and by contract with the corporation controlled the expenditure of the invested money on exploration.

principal business