Words and Phrases - "exclusively"

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13 May 2024 External T.I. 2022-0944461E5 - NPO - Residential housing co-operative

Summary Under
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l)
renting common areas out to third parties would disqualify a residential housing co-operative continue to qualify as an NPO under s.149(1)(l)

Would a residential housing co-operative (Co-op) continue to qualify under s.149(1)(l) if it earned profits from renting its common areas to...

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Words and Phrases
exclusively incidental

Tourbec (1979) Inc. v. Minister of National Revenue, [1988] 2 CTC 2071, 88 DTC 1442

Summary Under
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l)
NPO carrying on a profitable travel agency business did not qualify

In finding that the appellant, which was incorporated as a non-profit company, but which “was carrying on a business concern much the same as...

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Words and Phrases
exclusively