Elm Ridge Country Club Inc. v. Minister of National Revenue, [1999] 3 CTC 163 -- text

Décary J.A.:

The main issue in this appeal from a decision of the Tax Court of Canada[1] is the appellant golf club’s tax exemption in respect of income from sources other than property under subparagraph 149(5)(^)(i) of the Income Tax Act, R.S.C. 1985 (5th Suppl.), c. 1, as amended (“the Act”), on the basis that it is a non-profit organization “the main purpose of which is to provide dining, recreational or sporting facilities for its members” (a “club”).

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