2020 SR&ED TAX CASES
| SR&ED TOPIC | APPELLANT | PRIMARY ISSUE | WIN / LOSS | RULING & RATIONALE | IMPLICATIONS & OPPORTUNITIES | SIGNIFICANCE | |
|---|---|---|---|---|---|---|---|
| Technological eligibility | |||||||
| Oracle dev + witness deceased | Clevor | Evidence - PI deceased | LOSS | incomplete API for changes | provides discussion of "metaheuristics" | MODERATE | |
| Custom structure | Kam Press Metal | Technological Advancement | LOSS | lack of experience with acrylic | Loss with costs | MODERATE | |
| Distributed computing | CRL Engineering | Evidence & Advancement | WIN | weekly system snapshots | sequentially, progressively complex options | MODERATE | |
| Drilling evidence for SRED | Exxon | Technological Advancement | LOSS | commercial vs. technical focus | validation of existing method not SR&ED | MODERATE | |
| Concrete process development | Beton Mobile | Technological Advancement | WIN/LOSS | 6 of 14 projects eligible | questions on why some ineligible | HIGH | |
| Financial issues | |||||||
| CCPC status | CO2 Solution technologies | Control by public co. | LOSS | Defacto control established | Loss with costs | MODERATE | |
| Use of SR&ED pool & losses | Dean's Knight Income | Acquisition of control | WIN | No acquisition of control | Income allocated to use losses | HIGH |