SR&ED

In Northwest Hydraulic Consultants Ltd v R, 1998 CarswellNat 696, 98 DTC 1839 , the Tax Court of Canada considered whether certain scientific and technical work conducted by the appellant qualified as scientific research and experimental development (SR&ED) under the Income Tax Act, RSC 1985, c 1 (5th Supp) for the purpose of tax...

Eligible Canadian Public Corporations & SR&ED Historically, only Canadian Controlled Private Corporations (“CCPC”) have been eligible to claim Scientific Research & Experimental Development (“SR&ED”) tax incentives. However, now eligible Canadian public corporations (i.e., publicly‑listed...

SR&ED and Contemporaneous Documentation The SR&ED (Scientific Research and Experimental Development) policy in Canada advises that taxpayers claiming tax incentives for R&D activities maintain “contemporaneous documentation.” This refers to keeping detailed, accurate, and up-to-date records to...

New CRA Policy on Gross Negligence Penalties for SR&ED Claims The Canada Revenue Agency (CRA) has updated its enforcement approach for Gross Negligence Penalties under subsection 163(2) of the Income Tax Act, affecting Scientific Research and Experimental Development (SR&ED) claims. Effective January 28, 2025,...