Cases
KAM-PRESS METAL PRODUCTS LTD. v. HER MAJESTY THE QUEEN, 2021 FCA 88
6398316 Canada Inc. v. The Queen, 2021 TCC 17
Jentel Manufacturing Ltd. v. Canada, 2012 DTC 5031 [at 6682], 2011 FCA 355
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See Also
WRD Borger Construction Ltd. v. The Queen, 2021 TCC 40 (Informal Procedure)
Logix Data Products Inc. v. The Queen, 2021 TCC 36
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | individual did not qualify as a participant expert | 128 |
Allegro Wireless Canada Inc. v. The Queen, 2021 TCC 27
National R&D Inc. v. The Queen, 2020 TCC 47
Béton mobile du Québec Inc. v. The Queen, 2019 CCI 278
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) - Subparagraph 37(8)(a)(ii) - Clause 37(8)(a)(ii)(B) - Subclause (8)(a)(ii)(B)(IV) | managerial and supervisory payroll included | 256 |
Clevor Technologies Inc. v. The Queen, 2019 TCC 166 (Informal Procedure)
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Exxonmobil Canada Ltd. v. The Queen, 2019 TCC 108
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(3) - Paragraph 1204(3)(a) | income not derived from transporting if no actual revenues therefrom | 378 |
CRL Engineering Ltd. v. The Queen, 2019 TCC 65 (Informal Procedure)
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Concept Danat Inc. v. The Queen, 2019 TCC 32 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) - Paragraph 37(1)(a) - Subparagraph 37(1)(a)(i) | SR&ED claim could not be based on estimated hours worked | 141 |
Mac & Mac Hydrodemolition v. The Queen, 2017 TCC 256 (Informal Procedure)
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Life Choice Ltd. v. The Queen, 2017 TCC 21 (Informal Procedure)
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Flavor Net Inc. v. The Queen, 2017 TCC 179 (Informal Procedure)
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Robotx Solutions Inc. v. The Queen, 2017 TCC 73 (Informal Procedure)
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Formadrain Inc. v. The Queen, 2017 TCC 42 (Informal Procedure)
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Joel Theatrical Rigging Contractors (1980) Ltd. v. The Queen, 2017 TCC 6 (Informal Procedure)
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Words and Phrases
trial and errorEmotion Picture Studios Inc. v. The Queen, 2016 DTC 1005 [at 2519], 2015 TCC 323 (Informal Procedure)
ACSIS EHR (Electronic Health Record) Inc. v. The Queen, 2015 DTC 1212 [at 1366], 2015 TCC 263
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Hypercube Inc. v. The Queen, 2015 DTC 1135 [at 859], 2015 TCC 65 (Informal Procedure)
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6379249 Canada Inc. v. The Queen, 2015 DTC 1109 [at 638], 2015 TCC 77
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Feedlot Health Management Services Ltd. v. The Queen, 2015 TCC 32
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) - Subparagraph 37(8)(a)(ii) - Clause 37(8)(a)(ii)(B) | work by proxy need not be "for" SRED - only "in respect of" it | 320 |
1726437 Ontario Inc. (AirMax Technologies) v. The Queen, 2013 DTC 1008 [at 54], 2012 TCC 376 (Informal Procedure)
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Murray Arlin Dentistry Professional Corporation v. The Queen, 2012 DTC 1149 [at 3339], 2012 TCC 133 (Informal Procedure)
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Soneil International Limited v. The Queen, 2011 DTC 1282 [at 1592], 2011 TCC 391
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Advanced Agricultural Testing Inc. v. The Queen, 2009 DTC 687, 2009 TCC 190
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(10) | 27 |
Zeuter Development Corporation v. The Queen, 2007 DTC 41, 2006 TCC 597 (Informal Procedure)
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Tacto Neuro Sensory Devices Inc./Appareils Neurosensoriels Tacto Inc. v. The Queen, 2005 DTC 457, 2004 TCC 341
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Maritime-Ontario Freight Lines Limited v. The Queen, 2003 DTC 1410, 2003 TCC 674 (Informal Procedure)
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C W Agencies Inc v. The Queen, 2000 DTC 2372 (TCC), aff'd 2002 DTC 6740, 2001 FCA 393
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | 105 |
Knowledge Systems Inc. v. The Queen, 2000 DTC 2353 (TCC)
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Safety Plus Inc. v. The Queen, 99 DTC 537 (TCC)
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116736 Canada Inc. v. The Queen, 98 DTC 1816 (TCC) (Informal Procedure)
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Data Kinetics Ltd. v. The Queen, 98 DTC 1877 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) | 144 |
Northwest Hydraulic Consultants Ltd. v. The Queen, 98 DTC 1839 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 72 |
Telecomsyst Services Inc. v. The Queen, 97 DTC 684 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 94 |
Progressive Solutions Inc. v. The Queen, 96 DTC 1232 (TCC)
ETA Performance Systems Corp. v. MNR, 93 DTC 451, [1993] 1 CTC 2710 (TCC)
Canalerta Technologies Inc. v. MNR, 93 DTC 165, [1993] 1 CTC 2141 (TCC)
Revelations Research Ltd. v. MNR, 92 DTC 1036, [1992] 1 CTC 2136 (TCC)
Administrative Policy
6 February 2014 External T.I. 2013-0512191E5 - Mining Activities and SR & ED
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18 September 2013 Draft examples to illustrate key concepts in the Eligibility of Work for SR&ED Investment Tax Credits Policy
Eligibility of Work for SR&ED Investment Tax Credits Policy, 24 April 2015
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 158 |
Eligibility of Work for SR&ED Investment Tax Credits Policy, 24 April 2015
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 597 |
19 November 2012 External T.I. 2012-0459351E5 - Shale Gas Well Drilling Classification
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.2 - Subsection 66.2(5) - Canadian development expense - Paragraph (a) | 126 |
Scientific Research and Experimental Development Directorate: "The CRA's perspective on the New SR&ED Claim Form", Tax for the Owner-Manager, Vol. 9, No. 4, October, 2009, p. 1.
Application Policy SR & ED 2002-02R "Experimental Production and Commercial Production With Experimental Development Work - Allowable SR&ED Expenditures".
Application Policy SR & ED 96-09 "Eligibility of Clinical Trials to Meet Regulatory Requirements"
Application Policy SR & ED 96-08 "Eligibility of the Preparation of New Drug Submissions"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 0 |
Application Policy SR & ED 96-07 "Prototypes, Custom Products/Commercial Assets, Pilot Plants and Experimental Production"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 0 |
Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 0 |
SR & ED 95-03 "Claims for ISO 9000 Registration"
SR & ED 95-02R "Science Eligibility Guidelines for the Oil & Gas of Mining Industries"
SR & ED 95-01R "Linked Activities - Regulation 2900(1)(d)"
IC86-4R3 "Scientific Research and Experimental Development"
IT-151R4 "Scientific Research and Experimental Developmental Expenditures"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 0 |
Application Policy SR & ED 96-08 "Eligibility of the Preparation of New Drug Submissions"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 0 |
Application Policy SR & ED 96-07 "Prototypes, Custom Products/Commercial Assets, Pilot Plants and Experimental Production"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 0 |
Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 0 |
IT-151R4 "Scientific Research and Experimental Developmental Expenditures"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 0 |