Archives - novembre 2015

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  R&D PRO v. R. - TCC: Development of a chocolate spread not SRED

  27 novembre 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: The taxpayer claimed SRED credits in respect of a project to develop a chocolate spread made from cocoa butter and milk protein. The Tax Court held that while the project was methodical and systematic it did not involve sufficient technological risk or uncertainty to amount to SRED. The appeal was dismissed without costs as this was an informal procedure appeal.
  R&D PRO v. R. - TCC: Development of a chocolate spread not SREDPlus >
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  ITC Invoice (20376525 Ontario) v. R. - TCC: Development of factoring software not SRED

  18 novembre 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: The taxpayer operated a factoring business. In the course of that business it developed factoring software known as Factorsuite. It claimed SRED credits in respect of the development cost of Factorsuite and CRA denied the credits. It appealed to the Tax Court. The Court held that the Factorsuite project did not amount to SRED because it did not entail a sufficient degree of uncertainty. They were retooling off the shelf programs.
  ITC Invoice (20376525 Ontario) v. R. - TCC: Development of factoring software not SREDPlus >
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  ACSIS EHR v. R. - TCC: SREDs for creation of health info system in Belize

  11 novembre 2015 By Bill Innes

  catégories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: The taxpayer designed and implemented a nation-wide health information system for the nation of Belize. It claimed SRED credits which the Minister denied on the basis that the work “did not resolve any scientific or technical uncertainties” (para. [5]).
  ACSIS EHR v. R. - TCC: SREDs for creation of health info system in BelizePlus >