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13 May 2024 External T.I. 2022-0944461E5 - NPO - Residential housing co-operative -- summary under Paragraph 149(1)(l)

Would a residential housing co-operative (Co-op) continue to qualify under s.149(1)(l) if it earned profits from renting its common areas to third-parties (e.g., film companies) – and would the answer change if it did so through a wholly-owned taxable subsidiary?

By services, 20 August, 2024

Tourbec (1979) Inc. v. Minister of National Revenue, [1988] 2 CTC 2071, 88 DTC 1442 -- summary under Paragraph 149(1)(l)

In finding that the appellant, which was incorporated as a non-profit company, but which “was carrying on a business concern much the same as any other travel agency” and from which “it made quite considerable profits” did not qualify under s. 149(1)(l), Couture DJ first quoted the statement in British Launderers Research Association v. Central Middlesex Assessment Committee and Hendon Rating Authority, [1949] 1 All E.R. 21 that:

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