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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. ...

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. ...

Canada, 2012 DTC 5031 [at at 6682], 2011 FCA 355-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer, a producer of plastic containers, undertook a project to "improve the existing product to make it a smaller and significantly lighter storage system" (para. 9 of Statement of Appeal, quoted at para. 5). ...

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. ...

The Queen, 2015 DTC 1212 [at at 1366], 2015 TCC 263-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development new knowledge required to adapt software to poor local infrastructure The taxpayer had to adapt its existing system for implementing a nation-wide health information system in Belize given the severe telecommunications and internet connectivity issues there. ...