Dr. Gerald Penn

1 total

NM

Software development projects involving wireless technology qualified as SR&ED due to technological uncertainty and systematic investigation.

The Appellant appealed reassessments for its 2010 and 2011 taxation years, arguing that certain software development projects qualified as scientific research and experimental development (SR&ED).

The Tax Court of Canada found that the projects involved technological uncertainty that could not be resolved by routine engineering and that the Appellant formulated and tested hypotheses to achieve technological advancements.

The appeals were allowed, and the reassessments were referred back to the Minister to allow the claimed SR&ED expenditures and corresponding investment tax credits.