•In
CRA View 2011-0427611I7, after evaluating the information
presented to it, CRA determined that the NPOs profits were
consistently increasing every year, that its profits were not
incidental, and that its profit margins were such that the
Organization had a for profit purpose
•Of
particular concern was that the NPOs members equity had also
increased over the years such that CRA believed that the
organization could be accumulating funds in order to earn
tax-exempt investment income
•CRA
concluded that the NPO had not been operating for a purpose other
than profit and did not meet the requirements of paragraph
149(1)(l)