profits

A non-share federal corporation that undertook audience measurement activities for the benefit of its members (commercial TV and radio stations) qualified as a not-for-profit organization. Boyle J. stated (at paras. 49-50):

If its reserves are reasonable and it operates on a cost recovery basis, it would be hard to say an organization realizes significant profits.

BBM only sells its data to its members. It would be difficult to impute a profit purpose to an organization that only sells to members on a cost recovery basis.

Cattanach J. stated respecting the word "profits" in Regulation 1201:

"I can see no justifiable reason for construing the word 'profits' as used in the Regulation in any sense different from the meaning attributed by authorities to that same word as used in the Income Tax Act."

The authorities defined "profits" as "the difference between the receipts from a business for the year and the expenses laid out to earn those receipts."