Précis: The taxpayer operated a RV/Mobile Home campsite from April to October and, for a fee, campers could keep their RV/Mobile Home on site during the off-season. The taxpayer earned campsite fees, storage fees and, later, fees as a dealer of mobile units. The Court found that the campsite activity did not cross the threshold from property income to income from the provision of services. As a result, the taxpayer was a specified investment business (SIB) not entitled to the small business deduction (SBD). The appeal was therefore dismissed with costs.
1717398 Ontario Inc. O/A Lost Forest Park v. R. – TCC: Corporate income did not meet the threshold to qualify for small business deductionREAD MORE »