2021 SR&ED TAX CASES
| SR&ED TOPIC | APPELLANT | PRIMARY ISSUE | WIN / LOSS | RULING & RATIONALE | IMPLICATIONS & OPPORTUNITIES | SIGNIFICANCE | |
|---|---|---|---|---|---|---|---|
| TECHNOLOGICAL ELIGIBILITY | |||||||
| Claims by Medical Prof. Corps. | Andre Lamy MPC | Who does SR&ED? | Win | PI work on clinical trial eligible | 4 eligible projects - 2 with sponsors | High | |
| Software for marine travel | Indusol | Systematic Investigation (SI) | Lose + costs | No SI even though TU | Need to show progressive hypotheses | Moderate | |
| Software for SR&ED claims | National R&D | Systematic Investigation (SI) | Lose + costs | No SI even though TU | Need to show progressive hypotheses | Moderate | |
| FINANCIAL ISSUES | |||||||
| Claims by Medical Prof. Corps. | Andre Lamy MPC | Whether Directly Engaged | Win | Work by Dr. on behalf of MPC | Major precedent for contract structures | High | |