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The Queen, 2021 TCC 27-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development software development qualified as SR&ED The taxpayer provided a software platform to its clients to allow them to communicate remotely with their workers through wireless handheld devices used to access their employer’s computer system, in a great variety of applications. ... Agencies, found (at para. 194) that the taxpayer “was attempting to develop a new product (its platform) that would work seamlessly with a multitude of devices that used different operating software and ran on the various operating systems of [its] clients” and similarly (at para. 202) that the work undertaken by the taxpayer was "for the purpose of achieving technological advancements that would allow [it] to create a new and/or better product” found that the project had various challenging elements and that these challenges could not be resolved with routine engineering, so that it was instead required to experiment to come up with hypotheses of things that it could test also noted (at para. 209) the projects “were the same or similar to projects in respect of which the Appellant received grants from the National Research Council of Canada” Before allowing the appeal, he stated (at para. 208) … I have concluded that when the Appellant conducted the projects at issue, it formulated hypotheses specifically aimed at reducing the identified technological uncertainty, followed appropriate procedures on testing, including the formulation, testing, and modification of hypotheses, and maintained a detailed record of the hypotheses tested and results achieved as the work progressed. ...

Procon Mining & Tunnelling Ltd. v. The Queen, 2022 TCC 71, aff'd 2024 FCA 1-- summary under Capital Loss v. ... Boyle J went on to state (at para. 23): The Appellant maintains that, since its intention at the time of acquisition was to earn business income, the loss at issue was a business loss. … [T]his is not the test. ... It is almost antithetical to the correct distinction between the two types of property to say that the property acquired to be held and used to generate revenues from its business, which does not include trading in such property, is not capital property when sold …. ...

The Queen, 2011 DTC 1216 [at at 1274], 2011 TCC 289-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment through back-to-back promissory notes In settlement of a suit by the taxpayer, who was an income beneficiary, the settlement agreement provided for the payment by the trust to her of $1.7 million in satisfaction of her interest in the trust. ...

The Queen, 2015 DTC 1109 [at at 638], 2015 TCC 77-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development incremental improvements to an already-launched device were experimental development After developing and commercially launching a miniature portable printer, the taxpayer pulled the product in 2009 after identifying problems with curling paper and battery life. ...

The Queen, 2015 TCC 32-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development feed for cattle to be used for beef after SR&ED testing was excluded The taxpayer, a veterinary consulting firm, undertook four research projects to test new diets, supplements, and vaccines on cattle, and paid feedlot operators to perform these protocols. ...

The Queen, 2012 DTC 1149 [at at 3339], 2012 TCC 133 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Woods J. found that it was not reasonable for the taxpayer, a professional corporation belonging to Dr. ...

Richter & Associates Inc v. The Queen, 2005 TCC 92-- summary under Paragraph 141.1(3)(b) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(b) action brought by trustee for bankrupt financial institution deemed to be not in course of commercial activity The trustee in bankruptcy for a company ("Castor") which had essentially only engaged in investing in high-yield loans brought an action in its capacity of trustee for the Castor estate against the former auditors ("C&L") for $40 million in damages for breach of contract, and also began a "litigation support business" of providing assistance to most of the creditors (the "Participating Creditors"), including hiring professionals and experts, in connection with their action sounding in negligence against C&L for $800 million in damages. ... Therefore, the costs of the litigation support services that the Estate enjoyed in prosecuting its own claim against C&L would not qualify for ITCs. … However, the portion of the services and properties in question that was acquired for the purpose of prosecuting the claims of the Participating Creditors would be considered to have been acquired in the course of commercial activities. ...

G & J Muirhead Holdings Ltd. v. The Queen, 2014 DTC 1067 [at at 3009], 2014 TCC 49 (Informal Procedure)-- summary under Personal Services Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business intentions in services contract are irrelevant; overtime rates The taxpayer was owned by its sole employee ("Muirhead") and his wife, and provided well inspection services to an arm's length corporation ("Harvest") under a services contract with it. The taxpayer had a personal services business – but for the services contract, Muirhead would have been a Harvest employee. ...

The Queen, 2011 DTC 1117 [at at 628], 2011 TCC 148, aff'd 2012 DTC 5138 [at 7292], 2012 FCA 214 supra-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no implied set-off The taxpayer acquired a 100% undivided interest in a property (the "Quarter Claim") adjoining its "Golden Giant" mine subject to a 50% net profits royalty in favour of the vendor ("Teck/Corona"). ...

The Queen, 2013 DTC 1008 [at at 54], 2012 TCC 376 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer, which installed heating, air conditioning and ventilation systems in residential homes, claimed SR&ED credits relating to its "High Static High Velocity Fan Coil System Development" project. ...