Ontario Builders Ltd. is a Canadian-controlled private corporation located in Ontario. For its fiscal year ended December 31, 2021, the corporation had correctly calculated its income for tax purposes under Division B as follows: Operating income (Note 1) $ 387,000 Profit on the sale of excess land (Note 2) 305,000 Royalty income (Note 3) 15,000 Retailing income 210,000 Interest on o/s accounts receivable in retailing business 14,500 Recapture of CCA (Note 4) 30,500 Advertising agency loss (53,500) Rental income (Note 5) 36,500 Taxable capital gains net of losses (from active assets) 63,000 Interest income from five-year bonds 10,000 Div from non-connected taxable Canadian corporations(eligible) 9,000 Foreign non-business income in Cdn. $ (Note 6) 25,000 Division B net income for tax purposes $1,052,000 The CCPC had also correctly calculated its taxable income as follows: Charitable Donations Dividends Non-capital losses Net capital losses Division C Taxable income Notes: (28,000) (9,000) (46,500) (14,500) $954,000 1) This amount of operating income was computed correctly under Division B. The corporation has only one permanent establishment in Ontario. 2) The land had been held for approximately three years. It had been held vacant in order to realize a profit on its sale at the right time. 3) The royalty income had been determined to be property income. 4) The recapture resulted from the sale of some fixtures used in the retailing business. 5) The rental income was derived from leasing the entire space on a five-year lease in an unused warehouse. 6) Withholding tax on the pre-tax non-business income of $25,000 was C$5,000.