CRA considers that the stipulated rights of lessee should be valued for SBC and QSBCS purposes

Although CRA considers it to be irrelevant whether, under GAAP, a lease is capitalized by a lessee as a capital lease, it considers that the rights of a lessee specified in its lease are property whose fair market value (if any) should be taken into account in determining whether the lessee is a small business corporation or whether its shares are qualified small business corporation shares – so that if the leased property is used principally in a Canadian active business, this will help towards satisfying those definitions– and, conversely, if it is not.

Neal Armstrong. Summary of 7 October 2016 APFF Roundtable, Q.11 under s. 248(1) – small business corporation.