SR&ED tax credits allowed; medical professional corporation, not the individual doctor, conducted the research.
The Appellant, a medical professional corporation, appealed the Minister's disallowance of scientific research and experimental development (SR&ED) tax credits for the 2013 and 2014 taxation years.
The Minister conceded that the research projects constituted SR&ED and that the claimed amounts were spent, but argued the research was conducted by Dr. Lamy in his personal capacity rather than by the Appellant.
The Tax Court of Canada allowed the appeal, finding that Dr. Lamy performed the research as an employee of the Appellant, as evidenced by his employment agreement and the fact that the Appellant paid his salary for the research work.
