Ikea Ltd. v. Canada, 98 DTC 6092, [1998] 1 S.C.R. 196, [1998] 2 C.T.C. 61 -- summary under Compensation Payments

A tenant inducement payment which the taxpayer (a furniture retailer) became entitled to receive as a result of entering into a lease of premises, was not a tax-free capital receipt. The payment was not received as a reimbursement for the cost of capital property (the payment was made free of any conditions for or stipulations as to its use). The taxpayer's obligations under the lease essentially consisted of the payment of rent and the operation of its business in the leased premises. These were clearly expenses incurred in the day-to-day operations of the business and were therefore on revenue account. Whether the tenant inducement payment represented a reduction in rent or consideration for the taxpayer's assumptions of these revenue account obligations, it should be included in its income.