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Appeal dismissed; taxpayer's consulting and management services constituted a personal services business ineligible for small business deduction.
The Appellant appealed reassessments denying its claim for the small business deduction on the basis that it carried on a personal services business.
The Appellant argued it was associated with the companies to which it provided services, which would exempt it from the personal services business rules but still deny the small business deduction, in an attempt to claim the general rate reduction.
The Tax Court of Canada found that the Appellant was not associated with the client companies and that the profit-sharing revenue it received was income from a personal services business.
The appeal was dismissed.
