CRA is reviewing the Medallion decision

In Medallion, a corporation that acted as a property manager for the rental properties of 10 non-arm’s length owner-corporations in consideration for a percentage of the rents, was found to qualify as the participant in a joint venture, notwithstanding that it had no ownership interest in the properties, so that it had validly elected to be the JV operator. In response to a question as to whether a participant in a joint venture includes a person who contributes solely property management services to the joint venture pursuant to a written joint venture agreement, CRA responded:

We are currently reviewing the extent to which the Medallion decision would affect our position with respect to the issue of who can be considered to be a participant in a joint venture for purposes of section 273 …, and this includes taking into consideration the issue described in the question.

Neal Armstrong. Summary of 28 February 2019 CBA Roundtable, Q.23 under ETA s. 273(1).