•CRA
stated that since the organization’s reasons for distributing
the amounts collected from users to Members was due to
non-profit reasons, it was reasonable to expect that the funds
would be invested
•The
profit from these funds could only be used to help meet
operating expenses and not to generate investment income
•If
the investment income was the income of the members and not of the
organization (i.e. the organization was an agent of the
members with respect to the income), then the investment income would
be taxed in the hands of the members and would not affect the tax
status of the organization as an NPO
•