Rocheleau v. The Queen, 2010 DTC 1016 [at at 2615], 2009 TCC 484 (Informal Procedure) -- summary under Class 14

A contract under which the taxpayer made a total contribution of $25,500 in consideration for a company agreeing to pay to the taxpayer 5.5% of the gross revenue from the operation of a lottery terminal in St. Petersburg, Russia for 10 years (with such company operating the terminal) only gave the taxpayer a right to earn income from property, and did not represent a concession or licence. Furthermore, as the agreement would not give rise to business income, the expenditure did not qualify as an eligible capital expenditure.