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FCA (summary)
National R&D Inc. v. Canada, 2022 FCA 72 -- summary under Scientific Research & Experimental Development
Canada, 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 need for use of the scientific method in SR&ED In response to the taxpayer’s submission that the Tax Court judge erred in relying on the test from Northwest Hydraulic in that it was not a requirement for SR&ED eligibility that the scientific method be followed, and that the scientific method contemplated by Northwest Hydraulic and applied by the judge differed from the engineering method, Rennie JA indicated: Kam-Press “affirmed that the Northwest Hydraulic criteria are the appropriate interpretation of the definition of scientific research and experimental development in subsection 248(1)” (para. 9). ...
TCC (summary)
Buhler Versatile Inc. v. The King, 2023 TCC 18 -- summary under Scientific Research & Experimental Development
The King, 2023 TCC 18-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development increasing the horsepower of a tractor by 20% was SR&ED Wong J allowed the claim of the taxpayer, which was the only Canadian manufacturer of agricultural tractors, respecting a project to build a four-wheel drive tractor with 85 horsepower (or about 20%) above the current industry maximum. ...
Technical Interpretation - Internal summary
15 November 2002 Internal T.I. 2002-0162427 F - Price Adjustment Clause & 85(7.1) -- summary under Effective Date
15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date large FMV discrepancy suggested lack of bona fide valuation so that price adjustment clause need not be applied/ if applied, s. 85(1) election must be amended Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. ... The jurisprudence has shown that a price adjustment clause can be ignored in cases where there is no good faith effort to determine the FMV of a property (See: Guilder News ….). On this basis, it seems to us that you would be free to ignore the price adjustment clause and therefore maintain an assessment under 85(1)(e.2). … [If] you decide to recognize the price adjustment clause … the taxpayer must file an amended election to give effect to the price adjustment clause. ...
Current CRA website
Appendix B – Certificate of zero-rated entitlement – Example Image
Appendix B – Certificate of zero-rated entitlement – Example Image From: Canada Revenue Agency Previous page Page details Date modified: 2009-06-08 ...
Technical Interpretation - Internal summary
2 April 2019 Internal T.I. 2016-0649821I7 F - Unclaimed superannuation or pension benefits -- summary under Payment & Receipt
2 April 2019 Internal T.I. 2016-0649821I7 F- Unclaimed superannuation or pension benefits-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amount received in Year 2 in lieu of pension benefit includes source deductions in Year 1 Although CRA usually applies its constructive receipt concepts in the context of employment income recognition, it has applied that concept to pension income recognition under s. 56(1)(a)(i). ... Its reasoning was that the amount could not be considered to be “received” as a pension benefit in the year of payment by the RPP administrator to the Directorate because the right-holder had not yet been identified – whereas in the subsequent year of payment over by the Directorate to the right-holder, that right-holder is receiving that amount under s. 56(1)(a)(i) as being “in lieu of” a superannuation or pension benefit. ...
Current CRA website
Line 25500 – Prescribed Zones – Manitoba
Line 25500 – Prescribed Zones – Manitoba Place names followed by numbers are Indian reserves. ... Manitoba Table of the prescribed northern or intermediate zones for Manitoba Zone A – Prescribed Northern Zones Zone B – Prescribed Intermediate Zones Amery Back Belcher Bird Brochet Brochet 197 Burge Lake Provincial Recreation Park Bylot Charlebois Chesnaye Churchill Cromarty Digges Drybrough Duck Lake Post Fort Churchill Fort Hall Fox Lake (Bird) 2 Fox Lake 1 Fox Mine Garden Hill Gillam Gods Lake Gods Lake 23 Gods Lake Narrows Gods River Herchmer Herriot Island Lake Island Lake 22 Island Lake 22A Jacam Johnsonkank Kakapawanis Kapaneewekamik Place Kapuskaypachik Kellett Kettle (generating station) Kettle Rapids Kitchiokonim Place Kitchisakik Kosapachekaywinasinne Kosapechekanesik Lac Brochet Lac Brochet 197A Lamprey Lawledge Le Pensie Leaf Rapids Limestone (railway siding) Long Spruce Long Spruce (generating station) Luke Lynn Lake Matawak Mathias Columb (Granville Lake) M'Clintock McVeigh Mistuhekasookun Nonsuch North Knife Lake North River Nunalla O'Day Omineeseenowenik Oxford House Oxford House 24 Piponshewanik Port Churchill Port Nelson Red Sucker Lake Red Sucker Lake 1976 Ruttan Mine St. ...
Current CRA website
Offshore Compliance Advisory Committee – Minutes – June 13, 2017
Offshore Compliance Advisory Committee – Minutes – June 13, 2017 Tuesday, June 13, 2017 List of Participants OCAC Members Chair Colin Campbell Vice-Chair Kimberley Brooks Committee Members Catherine Brown Larry Chapman Daniel Thornton- Absent CRA Attendees Deputy Assistant Commissioner, International, Large Business and Investigations Branch (ILBIB) Lisa Anawati Director, Business Intelligence and Analytics Division, ILBIB Randy Reynoso Director, Large Business Audit, ILBIB Gord Parr 1. ...
Current CRA website
Offshore Compliance Advisory Committee – Minutes – February 3, 2017
Offshore Compliance Advisory Committee – Minutes – February 3, 2017 Friday, February 3, 2017 List of Participants OCAC Members Chair Colin Campbell Vice-Chair Kimberley Brooks Committee Members Catherine Brown Larry Chapman Daniel Thornton CRA Attendees Deputy Assistant Commissioner, International, Large Business and Investigations Branch Lisa Anawati Director, International Tax Division, International and Large Business Directorate Alexandra MacLean Senior Technical Advisor, Offshore and Aggressive Tax Planning Directorate Phil Cherrett (by phone) 1. ...
Technical Interpretation - Internal
9 June 2003 Internal T.I. 2003-0011137 - SR & ED ARM'S LENGTH & CCPC STATUS
9 June 2003 Internal T.I. 2003-0011137- SR & ED ARM'S LENGTH & CCPC STATUS Also released under document number 2003-00111370. ...
TCC (summary)
WRD Borger Construction Ltd. v. The Queen, 2021 TCC 40 (Informal Procedure) -- summary under Scientific Research & Experimental Development
The Queen, 2021 TCC 40 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development taxpayer was engaged in trial and error rather than SR&ED The taxpayer’s business included installing water mains and culverts in housing subdivisions. ... I would describe the appellant’s efforts as resourceful in light of the time and monetary constraints before it, but they were not innovative. [20] … I would consider the use of physical objects and pumps in this manner to be within the scope of their standard usages. [21] The appellant’s approach to this situation was more akin to problem-solving by trial and error than formulating hypotheses and systematically testing them to reduce or eliminate a technological uncertainty. … [23] The fact that the appellant’s recordkeeping was limited to time cards and daily field observations entered into its routine monitoring system, supports the conclusion that the appellant was not engaged in experimental development to achieve technological advancement by creating something new or improving something already in existence. It was unnecessary to track progress as one would in a scientific experiment because there was no hypothesis. [24] … [T]here was no advancement in the field of civil engineering for the purposes of the SRED provisions. ...