10 July 1989 Ministerial Correspondence 58094 F - Activities Considered as Carrying on of a Business

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

July 10, 1989

19(1)

We are writing in reply to your letter of May 1, 1989, wherein you requested our views as to whether the activities described in your letter would be considered to be carrying on a business, the income from which would be subject to income tax.

24(1)

OUR COMMENTS

For income tax purposes, business is defined, in part, as including a profession, calling, trade, manufacture or undertaking of any kind whatever but does not include an office or employment.  Generally, business activities include any activity which is carried on for profit or with a reasonable expectation of profit.

From the limited information contained in your letter, it would appear that your activities may be considered an undertaking carried on with a view to profit or a reasonable expectation of profit.  Whether or not the net income derived from your activities (after taking into account related outlays and expenses) would result in income tax payable would depend on the facts of your own particular situation.

In the circumstances, you may wish to provide all relevant facts and documentation to the Thunder Bay District Taxation Office, 201 North May Street, for a determination as to whether the activities described in your letter constitute a business for income tax purposes.

We hope you find these comments helpful.

Yours truly,

E.M. Wheelerfor DirectorSmall Business and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch