CRA letter on qualifying as an NPO when excess funds available to purchase and finance a taxable org

Here is a recent letter from CRA dealing with whether a non-profit organization meets the requirements of paragraph 149(1)(l) of the Income Tax Act. In this case, the organization purchased and financed a taxable organization, and it appeared that there was a consistent amount of excess revenues in comparison to expenditures in some years. This suggests there may be a profit purpose. CRA found that the organization was not organized and operating for a purpose other than profit so it did not meet the requirements of paragraph 149(1)(l) of the ITA.