CRA applies general principles for determining whether TFSA trading is a business

S. 146.2(6) provides that if a TFSA “carries on one or more businesses” then Part I tax is payable on its business income.

After noting that CRA has reassessed more than $75 million in additional taxes resulting from audits of TFSAs, CRA indicated that the general principles in IT-479R apply to determining whether securities trading is a business, so that there is no need for guidance specific to TFSAs on this issue.

Neal Armstrong. Summary of 13 June 2017 STEP Roundtable, Q.13 under s. 146.2(6).