No. Substantiality is judged against the cost of the specific U.S. business being acquired or built, not the size of the sale that funded it. A large source of funds still needs to be matched to an appropriately substantial investment in a real operating enterprise.
Match the funding size to the actual business cost
Identify the total cost of establishing or acquiring the U.S. enterprise and compare the proposed investment to that figure specifically. A farm sale that generated significant proceeds does not by itself establish that the resulting investment is substantial relative to the new business — that comparison needs to be made directly.
Evaluate the U.S. enterprise, not the size of the Ontario sale. Both the investor and enterprise must possess treaty nationality; for a Canadian case that means Canadian citizenship, not permanent residence, and at least 50% treaty-national ownership of the enterprise. The investor must develop and direct it through 50% ownership or operational control. Substantiality is assessed by proportionality against the cost of the particular business, with no fixed minimum. Confirm that capital is at risk and irrevocably committed, and test whether the enterprise will be real, active, and non-marginal. The common mistake is treating impressive proceeds as automatic eligibility before mapping ownership, control, commitment, and business cost.
Hypothetical example: A Strathroy-Caradoc farm-machinery mechanic sells inherited acreage and plans to acquire a U.S. repair shop. The review traces only his share of proceeds, prices the shop and required working capital, and reads the purchase conditions and voting agreement. A large bank balance left freely withdrawable does not prove investment. If a non-treaty partner will own most shares or control operations, the Ontario sale amount cannot cure that structural failure.