CRA acknowledges fixing of the s. 129(6) deemed active business income rule

In contrast to a problem in the July 29, 2016 draft legislation, under recently enacted s. 129(10), where an Opco earns all its income as active business income from arm’s length third parties and pays rents to an associated “Rentco,” an appropriate sharing of the $500,000 business limit between Opco and Rentco is permitted.

Neal Armstrong. Summary of 29 November 2016 CTF Annual Roundtable, Q.15 under s. 125(10).