Immunovaccine - Tax Court finds that government loans made on non-commercial terms are "government assistance"

Under a federal program for fostering Maritimes development, the taxpayer received interest-free advances which were repayable only out of a percentage of future revenues.

Lamarre J. found that the advances were "government assistance" which reduced the taxpayer's SR&ED credits.  Although they were not subsidies or forgivable loans, they were "any other form of assistance," which she interpreted as including funds advanced on terms that a private investor would never consider.

Scott Armstrong.  Summary of Immunovaccine Technologies Inc. v. The Queen, 2013 TCC 103, under s. 127(9) - government assistance.