What is the test for carrying on business?

While McFadyen J.A. was in dissent in Wilson v. Hull, she gave a useful description of relevant factors: I will not endeavour to give a comprehensive definition of the term "carrying on business". That would be an impossible task. In any event, the question is essentially one of fact. From review of the authorities cited by counsel, and others, the following factors are relevant in deciding the question: (1) the judgment debtor must be engaged in some serious business activity in the jurisdiction as distinct from a pastime or hobby; (2) He/she must devote time, labour, skill or effort in the jurisdiction; (3) the activity carried on in the jurisdiction should be of some importance or significance to the business endeavour of the debtor; and (4) there should be some continuity or consistency to the business activity as distinct from an isolated transaction or series of transactions. (We need not decide if the term is broad enough to encompass one who occasionally purchases business goods on a casual basis and do not do so.) A person may carry on business in several places at the same time. While the phrase "carrying on business" obviously includes dealings which the person has with his or her customers, the phrase also encompasses other essential aspects of business, activities such as the acquisition of goods for resale or raw materials for manufacture.