Small Business Corporation

if Opco and Realtyco are held equally by two unrelated individuals, Realtyco is not an SBC if it holds more than 50% of its assets as debt of Opco

shares of public-company franchisor could be used in the franchisee’s business if required to be held by it

outstanding and uncashed cheques did not reduce cash

corp qualified as SBC where only business activity was unsuccessful efforts to sell its stock of equipment

excess cash not an active business asset

future income tax asset is not an asset – tax receivable is, but is an active business asset if it arose from active business

corporate-owned policy valued for SBC or QSBCS purposes at the cash surrender value even if non-shareholder lives are included

FMV of rights under a lease must be included

"substantially" and "principally"