2022 SR&ED TAX CASES
| SR&ED TOPIC | APPELLANT | PRIMARY ISSUE | WIN / LOSS | RULING & RATIONALE | IMPLICATIONS & OPPORTUNITIES | SIGNIFICANCE | |
|---|---|---|---|---|---|---|---|
| Technological eligibility | |||||||
| Claims by Telcom | Allegro Wireless | Whether SR&ED | Win | 3 of 3 projects eligible | examples including AI and software | High | |
| Air quality research | Airzone One | How vs. Why factors | Win | 4 of 6 projects eligible | cut-off between eligible and ineligible | High | |
| Energy efficiency | Global Sustainable | Technological Uncertainty | Loss | Work routine | compare vs. Airmax case | Moderate | |
| Solar panels | Logix Data | Documentation | Loss | Tests not recorded | good project if documentation | Moderate | |
| Construction | WRD Borger Construction | Systematic Investigation | Loss | Trial & error | business vs. technological problems | Low | |
| Concrete forming | Atelier Béton | Systematic Investigation | Loss | Documenting hypotheses | examples of missing variables by CRA | Moderate | |
| Financial issues | |||||||
| Loans as government assistance | CAE | If loan reduces SR&ED? | Loss | Related to SR&ED | need to separate R&D vs. non -R&D loans | Moderate | |