carried on business

20 July 2004 External T.I. 2004-0062031E5 F - Actif utilisé dans entreprise exploitée activement -- summary under Business

A corporation owned a large area of vacant land in Canada (for instance, in an industrial park) and, as the corporation wished to locate in the park, it subdivided and sold portions of the vacant lot, which was its only activity. In finding that this would not constitute carrying on business for purposes of the definition of "qualified small business corporation share," CRA first quoted the statement in IT-459, para. 3 that:

By services, 28 November, 2015

Timmins v. R., 99 DTC 5494, [1999] 2 CTC 133 (FCA) -- summary under Subsection 122.3(1)

The taxpayer was employed by the New Brunswick Department of Agriculture and Rural Development to assist in establishing and administering several dairy farms in Malawi, in consideration for which the Department received fees that were intended to cover its cost, cover overhead and make a small profit. In finding that the Department satisfied the requirement that it be carrying on a business, Noel J.A. stated (at p. 5498) that in applying the definition of business in s. 248(1):

carried on business