Hall v. MNR, 90 DTC 1431 (TCC)

The taxpayer received a subsidy in order to render a piece of land suitable for the cultivation of blueberries and not with respect to the operation of the blueberry farm. The purpose of the subsidy legislation was to generate additional jobs and not to increase income. Accordingly, this subsidy was a capital receipt to the taxpayer.

The taxpayer received a subsidy in order to render a piece of land suitable for the cultivation of blueberries and not with respect to the operation of the blueberry farm. The purpose of the subsidy legislation was to generate additional jobs and not to increase income. Accordingly, this subsidy was a capital receipt to the taxpayer.