Question juridique clé
Whether the Geneva minimum income received in 2007 is exempt from federal direct tax as a public subsidy under Art. 24 let. d LIFD.
Solution extraite
No. The payments were taxable because they were not gratuitous: receipt was tied to a binding compensatory activity, so the subsidy exemption did not apply.
Motifs extraits
The court held that Art. 24 let. d LIFD applies only if need, assistance purpose, and gratuitousness are cumulatively present. Although need may exist, the minimum income scheme required a contractual/legal counter-performance, which makes the payment onerous even if the activity has limited economic value.