A trust owned and leased commercial buildings and offered certain services to tenants of the buildings, namely electricity, heating, water, maintenance, cleaning and security services. The CRA stated that the trust could be considered to be carrying on a business given the nature of the services offered to tenants. It did not matter to the analysis that the trust hired a property manager for the buildings (presumably on the theory that the manger is merely the trust’s agent). The CRA referred to IT-434R paragraphs 2 and 4 in this regard. 2021-0900911C6, answer to question 3 at the 2021 APFF roundtable.
