CAE Inc. v. The Queen, 2021 TCC 57, aff'd 2022 CAF 178 -- summary under Investment Contract

By services, 19 September, 2021

CAE, which was engaged in manufacturing flight simulator systems, incurred over $700 million in R&D expenditures on further developing such systems, as to which it received “contributions” over a five-year period of $250 million from Industry Canada. Under the agreement with Industry Canada, CAE was required to repay 135% of the amounts advanced (or $337.5 million) beginning after the last advance was made and in escalating specified amounts over a 15-year period.

Ouimet J agreed (at para. 123) with CAE that the arrangement was a loan, before going on to find that it was government assistance.

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advance labelled by government as a "contribution" but unconditionally repayable was a loan
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