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., 98 DTC 1839, [1998] 3 CTC 2520 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development 5 factors test The taxpayer was an engineering consultant firm that specialized in the development, management and protection of water resources. ...

The Queen, 2011 DTC 1282 [at at 1592], 2011 TCC 391-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development D'Arcy J. denied the taxpayer's claimed SR&ED credits arising from the development of various electrical systems for use in wheelchairs- a power optimizer to switch power between the front and back wheels of a wheelchair or scooter, an inhibitor to ensure that a wheelchair remain stationary while being charged, a virtual battery system to derive 36 volts of potential from two 12-volt batteries, and a multi-voltage output charger. ...

The Queen, 98 DTC 1877, [1998] 4 CTC 2618 (TCC)-- 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 was engaged in researching and developing advanced data management and memory management software systems for large mainframe computers, and which had adopted the proxy method for calculating SR&ED expenditures, was able to include in s. 37(8)(a)(ii)(B)(I) the cost of a dedicated telephone line that was used to pass instructions and data from the taxpayer's employees in Ottawa (none of whom left Canada) to the staff of an independent company in Birmingham, Alabama whose mainframe computer the taxpayer was leasing for testing purposes. ...

The Queen, 2015 DTC 1135 [at at 859], 2015 TCC 65 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development development of code analysis software entailed standard techniques Lamarre ACJ found that the taxpayer's development of code analysis software for websites was not experimental development. ...

The Queen, 2020 TCC 47, aff'd 2022 FCA 72-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development programming costs were not SR&ED The taxpayer (“National”), which provided consulting services to clients, claimed to have made SR&ED expenditures of $68,029 and generated investment tax credits of $23,810 in connection with developing a computer program that would automate aspects filing SR&ED claims with the CRA through a web-based, cross-platform and cross-browser framework to track claimable SR&ED projects. ...

The Queen, 2017 TCC 21 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development no SR&ED without testing The taxpayer was a natural health product company. ... Dahl that is fatal to this appeal. … Boyle J further stated (at para 53): My decision in this case is in no way intended to suggest that literature reviews and consultations with other researchers cannot be qualifying activities giving rise to qualifying expenses as legitimate constituent parts of SR&ED activities. … ...

The Queen, 2015 TCC 323, 2016 DTC 1005 [at 2519] (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development experiments to maximize internet search rankings were not SR&ED The taxpayer was engaged in determining how on-page and off-page variables for websites interrelate to determine their Google (or other internet search engine) ranking and how to structure data to improve such ranking. In finding that this activity did not qualify as SR&ED, C Miller J stated (at para. 9) that “the experiments of submitting several different versions of websites to determine the significance of variables relies on existing technology in a routine manner,” and (at para. 10): Here, the advancement would be the determination of algorithms that relate variables for purposes of ranking sites. … I fail to see how it is a scientific advancement to figure this out. ...

The Queen, 2019 TCC 32 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development using existing equipment in developing a new product was not R&D The taxpayer, whose business was to embroider or imprint publicizing lettering on clothing engaged in three projects, none of which were found by Lafleur J to qualify as SR&ED. ... Similarly, I am not of the opinion that there was any advancement in the technology; in fact, this Court previously ruled that the newness of a product is not sufficient for demonstrating a technological advancement (Zeuter …). ...

The Queen, 2021 TCC 36-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development alleged SR&ED work was routine engineering The taxpayer was an information technology company that undertook development of dual-purpose shingle sized solar panels that would be indistinguishable at street level from asphalt shingles. In finding that the taxpayer’s work did not qualify as SR&ED, Monaghan J indicated that: she was “not convinced the Appellant had adequate information about the state of relevant knowledge in the field to assess whether there was a technological uncertainty” (para. 76).. solutions identified by the taxpayer to identified challenges, e.g., adding an air gap beneath the shingles to avoid over-heating, and adding support to deal with snow weight issues, appeared “to be the application of routine engineering” (para. 89). the taxpayer’s test results summary pages lacked significant details of the tests’ purposes, the observations made and conclusions drawn. furthermore, the “jurisprudence indicates that the documentation should be contemporaneous” whereas here it seemed likely that “the schematics and test descriptions the Appellant provided were … prepared.. when the CRA asked the Appellant for supporting documentation,” and similarly for testing summaries (para. 139). ...

The King, 2023 TCC 108-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development developing new pie recipes was SR&ED Canafric operated a food manufacturing business specializing in developing frozen pies for grocery chains and restaurants. ... Canafric averaged around six projects a year in which it would elaborate a recipe designed to meet the client’s requirements, test the recipe and send the sample product to a “taste panel” for evaluation – and evaluate the reasons for any failure. ...