CRA rules that making loss-utilization loans did not change a corporation’s principal activities

CRA ruled that the making of intra-group loans in order to soak up unutilized non-capital losses and credits would not disqualify a corporation’s activities as being "primarily the carrying on… of a business that is a Canadian film or video production business."  A similar point could arise under various principal business corporation definitions such as in s. 66(15) and Reg. 1100(12).

Neal Armstrong.  Summary of 2012 Ruling 2012-0426581R3 under s. 111(1)(a).