Principal Issues: Whether real estate commissions earned by a personal real estate corporation ("PREC"), which are paid from a brokerage in which the shareholder of the PREC has an indirect interest in, would be described in subparagraph (a)(i) of the definition of specified corporate income in subsection 125(7) of the Act.
Position: Question of fact.
Reasons: If all or substantially all of the income is from the provision of services to arm’s length persons other than the private corporation (i.e., the brokerage), then the income received would not be an amount described in clause (a)(i)(B) of the definition “specified corporate income” in subsection 125(7) of the Act.