This legal document details the case of Sennaike v. The King, 2025 TCC 122, a Canadian tax court decision concerning an appellant's claim of business losses from his participation in Amway for the 2019 and 2020 tax years. The court evaluated whether his Amway activities constituted a "source of income," employing a two-stage test to determine if the endeavor was pursued for profit or was primarily a personal pursuit, and if commerciality was sufficient. The judgment ultimately dismissed the appellant's appeals, finding a significant personal element in his Amway activities, particularly in self-development through Amway's leadership program, and concluding that his activities were not undertaken in a sufficiently commercial manner to be considered a source of income. This decision was influenced by the appellant's inadequate accounting practices and lack of a clear plan for profitability.
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Sam Cao, CPA
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