Northwest Hydraulic Consultants Ltd. v. R., 98 DTC 1839, [1998] 3 CTC 2520 (TCC) -- summary under Scientific Research & Experimental Development

By services, 28 November, 2015

The taxpayer was an engineering consultant firm that specialized in the development, management and protection of water resources. Of the five hydraulic model studies reviewed by Bowman TCJ., four were found to have a sufficient degree of technological uncertainty for the work to qualify as SR&ED. Bowman TCJ enunciated five factors to be considered in SR&ED determinations (at para. 16):

  1. Was there a technological risk or uncertainty which could not be removed by routine engineering or standard procedures?
  2. Did the person claiming to be doing SR&ED formulate hypotheses specifically aimed at reducing or eliminating that technological uncertainty?
  3. Did the procedures adopted accord with the established and objective principles of the scientific method, including the formulation, testing and modification of hypotheses?
  4. Did the process result in a technological advancement?
  5. Was a detailed record kept of the hypotheses, tests and results kept as the work progressed?
Topics and taglines
Topic
Income Tax Act - s. 248(1) - Scientific Research & Experimental Development
Tagline
5 factors test
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
337375
Extra import data
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