In Canada v. Paletta, the Federal Court of Appeal clarified that, in order for a business to exist, there must be an intention to earn a profit. Absent such intention, there is no business and therefore no “source of income”.
Gross Negligence Penalties
Two taxpayers were reassessed, a corporation and its sole shareholder. The shareholder sold financial products and life insurance policies through his corporation although, for some provinces, he had to conduct business as a sole proprietor due to provincial regulations.