Subsection 2900(2)
See Also
Armada Equipment Corporation v. The Queen, 2007 DTC 879, 2007 TCC 260 (Informal Procedure)
In finding that fees paid to an accounting firm to file claims for investment tax credits did not qualify as "directly related" to the prosecution...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 2902 | 90 |
Consoltex Inc. v. R., 97 DTC 724, [1997] 2 CTC 2846 (TCC)
The cost of yarn that the taxpayer expended in the course of R&D project qualified under both s. 37(7)(c)(ii)(A) and Regulation 2900(2)(c),...
Administrative Policy
Application Policy SR & ED 96-06 "Directly Undertaking, Supervising or Supporting v. 'Directly Engaged' SR & ED Salary and Wages".
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) | 0 |
28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)
Use of the term "paid" in s. 2900(2)(b) was intended to deny deductions for accruals of salaries, wages and bonuses. However, in order to assist...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | 37 | |
| Tax Topics - Income Tax Act - Section 189 - Subsection 189(1) | 37 |
23 April 1990 Memorandum (September 1990 Access Letter, ¶1412)
The concession in IT-151R3, para. 11 (that normal year-end accruals would be considered to have been "paid") is a practical but minor concession...
18 December 1989 Memorandum (May 1990 Access Letter, ¶1212)
Cost associated with bidding for a contract, do not satisfy the requirements of s. 2900(1)(c) because the bidding costs would have been incurred...
87 C.R. - Q. 27
Each employee's employment duties must be examined and a determination made as to whether his duties directly relate to the undertaking,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) | 21 |
IT-151R4 "Scientific Research and Experimental Development Expenditures"
Paragraph 2900(2)(b)
See Also
Manufacture Kute Knit Inc. v. Agence du revenu du Québec, 2024 QCCA 408
The taxpayer (Kute Knit), which was acknowledged by the ARQ to be engaged in SR&ED, had claimed percentages (ranging from 15% to 75%) of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | taxpayer failed to make out a prima facie case to demolish the premise of the ARQ assessments that it had not shown how much supervisory time related to SR&ED | 269 |
Manufacture Kute Knit Inc. v. Agence du revenu du Québec, 2022 QCCQ 3480, aff'd 2024 QCCA 408
The taxpayer (Kute Knit), which was acknowledged by the ARQ to be engaged in SR&ED, had claimed percentages (ranging from 15% to 75%) of the...
Focus Micro Ondes Inc. v. Agence du revenu du Québec, 2022 QCCQ 2070
The claim of the taxpayer (Focus) for the portion of the salaries of its employees that directly related to the prosecution of SR&ED as described...
Hubmar International Inc. v. Agence du revenu du Québec, 2021 QCCQ 12822
Although the ARQ accepted that the taxpayer was carrying on SR&ED, the taxpayer had failed to establish with any convincing evidence what...
AG Shield Ltd. v. The Queen, 2017 TCC 68
The taxpayer was a Canadian corporation, owned equally by two brothers, that carried on a small-scale business of designing and manufacturing...
| 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) | individual shareholders could allocate all of their non-dividend earnings to SR&ED wages | 180 |
Subsection 2900(4)
Administrative Policy
Prescribed Proxy Amount Policy 19 December 2012
The objective of the overall cap is to ensure that the total qualified SR&ED expenditures and PPA and other deductions specifically allowed under...
Subsection 2900(9)
Paragraph 2900(9)(c)
See Also
Oldcastle Building Products Canada Inc. v. The Queen, 2016 TCC 183
The taxpayer (“Oldcastle”), which was a leading producer of concrete building products, entered into an employment contract in 2004, with a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 2900 - Subsection 2900(9) - Paragraph 2900(9)(d) | percentage of net sales was not based on profits | 345 |
| 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) | sales-based comepensation nonetheless directly related to SR&ED | 441 |
Paragraph 2900(9)(d)
See Also
Oldcastle Building Products Canada Inc. v. The Queen, 2016 TCC 183
The taxpayer (“Oldcastle”), which was a leading producer of concrete building products, entered into an employment contract in 2004, with a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 2900 - Subsection 2900(9) - Paragraph 2900(9)(c) | sales-based remuneration was not bonus | 320 |
| 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) | sales-based comepensation nonetheless directly related to SR&ED | 441 |
Subsection 2900(11)
Administrative Policy
9 February 2010 External T.I. 2009-0316561E5 F - Biens en immobilisations-RS&DE
In a general response to a question in which there was a failure to provide cumulative use percentages, CRA stated:
[A]ssets used for SR&ED during...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - First Term Shared-Use Equipment | expected use throughout expected useful life is considered | 89 |