Elmridge Country Club Inc. v. The Queen, 99 DTC 5127 (FCA)

Interest income derived by a golf club from the temporary investment of cash surpluses were taxable. Décary J.A. rejected a submission that income from activities that were incidental to the non-profit activities of the club were not intended to be taxable.

The taxpayer, which was a country club that was found to be subject to tax on interest from the investment of surplus funds pursuant to s. 149(5), was not able to deduct interest on loans incurred by it from time to time to fund cash-flow shortfalls.