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    <title>Purpose test for subsidy classification finds sales tax exemption tied to capital investment is a capital receipt, not taxable.</title>
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    <description>Classification of a sales tax subsidy was determined by the purpose test: where an exemption is designed to encourage fixed capital investment and employment, linked to capital outlay and available for a limited period, its dominant object is to promote capital formation and not recurring operations. Time or manner of receipt is immaterial; the subsidy operates as an incentive for capital investment. Applying this principle, the court concluded the subsidy is a capital receipt and not taxable as revenue, and the challenge to retention by the assessee was rejected.</description>
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      <title>Purpose test for subsidy classification finds sales tax exemption tied to capital investment is a capital receipt, not taxable.</title>
      <link>https://www.taxtmi.com/highlights?id=97581</link>
      <description>Classification of a sales tax subsidy was determined by the purpose test: where an exemption is designed to encourage fixed capital investment and employment, linked to capital outlay and available for a limited period, its dominant object is to promote capital formation and not recurring operations. Time or manner of receipt is immaterial; the subsidy operates as an incentive for capital investment. Applying this principle, the court concluded the subsidy is a capital receipt and not taxable as revenue, and the challenge to retention by the assessee was rejected.</description>
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