Lori. McMillan (Washburn) has published The Concept of Income as Related to the Non-Charitable Non-profit Subsector in Canada, 16 Law & Bus. Rev. Am. 457 (2010). Here is the Introduction:

Whether or not something is "income" is a question that has frequently caused conflict since income taxation began. Usually, determining what constitutes income is important because it establishes liability for taxation. For purposes of this article, however, income classification is important for determining the existence of a public subsidy for certain nonprofit organizations currently exempt from federal income taxation in Canada. Although the nonprofit sector encompasses both charitable and non-charitable organizations, I will use the specific term "nonprofit" in this article to refer to non-charitable entities exempt from taxation by virtue of paragraph 149(1)(/) of the Income Tax Actl (ITA) (the "Provision"), explored later in this work.

This paper will examine the concept of "income" and will conclude that: (1) these entities can earn income and would therefore be properly subject to taxation but for the Provision; and (2) as a consequence, the exemption from taxation that nonprofits enjoy is a tax expenditure. Furthermore, the program supported by this spending should be evaluated to determine its effectiveness.