2025 SR&ED TAX CASES

APPELLANTSR&ED TOPICPRIMARY ISSUEWIN / LOSSRULING & RATIONALEIMPLICATIONSSIGNIFICANCE
Manning Canning Kitchens Inc.Shelf-stable cold-pressed juice ('Chrisoda')Technological uncertainty; scientific methodWINNovel HPP application for microbial stability in cold-pressed juice; systematic hypotheses tested via measurable observations (e.g., pH, microbial counts); adhered to scientific method with controlled trials; proven technological advancement in food preservationValidates observation & measurement as keys to systematic investigation; strengthens food/agri SR&ED claims requiring empirical data over routine processingHigh
Dazzm Inc.Cloud-based SaaS software integration (React Performance)Technological uncertainty; hypothesis formulationWINSystemic uncertainty in open-source tool integration (React, Redux, etc.), NW Hydraulic criteria, beyond routine debugging/optimizationEncourages holistic evaluation of software projects; reinforces documentation via metrics/testimonyHigh
Vortex Energy Services Ltd.Mobile direct-contact water heaters (fracking)Technological uncertainty; hypotheses; documentationLOSSWork was trial-and-error prototyping; vague/general hypotheses; no systematic method or measurable advancement; poor contemporaneous records and lack of expert evidenceReinforces need for verifiable, systematic documentation and technical validation to counter routine engineering assumptionsLow
Paveit Construction Inc.Roller-Compacted Concrete field processTechnological uncertainty; hypotheses; documentationLOSSAdjustments were trial-and-error; known variables; no advancement; poor recordsReinforces need for controlled, systematic evidenceMedium
Blackberry Canadaforeign R&D Whether foreign R&D FAPI incomeWINR&D services were not FAPIshould not be treated as passive incomeHigh