CRA indicates that a corporation with only property income does not accord excluded share status

CRA confirmed that where a corporation has no business income because it derives income from property (e.g., rental income that is property income), its shares cannot qualify as excluded shares. In particular, where both the business and service income are nil, it will not be considered to satisfy the requirement that less than 90% of its business income is from the provision of services.

Neal Armstrong. Summary of 29 May 2018 STEP Roundtable, Q.7 under s. 120.4(1) – excluded shares.