Subsection 2900(2)
See Also
Armada Equipment Corporation v. The Queen, 2007 DTC 879, 2007 TCC 260 (Informal Procedure)
In finding that fees paid to an accounting firm to file claims for investment tax credits did not qualify as "directly related" to the prosecution...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 2902 | 90 |
Consoltex Inc. v. The Queen, 97 DTC 724 (TCC)
The cost of yarn that the taxpayer expended in the course of R&D project qualified under both s. 37(7)(c)(ii)(A) and Regulation 2900(2)(c),...
Administrative Policy
Application Policy SR & ED 96-06 "Directly Undertaking, Supervising or Supporting v. 'Directly Engaged' SR & ED Salary and Wages".
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) | 0 |
28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)
Use of the term "paid" in s. 2900(2)(b) was intended to deny deductions for accruals of salaries, wages and bonuses. However, in order to assist...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | 37 | |
| Tax Topics - Income Tax Act - Section 189 - Subsection 189(1) | 37 |
23 April 1990 Memorandum (September 1990 Access Letter, ¶1412)
The concession in IT-151R3, para. 11 (that normal year-end accruals would be considered to have been "paid") is a practical but minor concession...
18 December 1989 Memorandum (May 1990 Access Letter, ¶1212)
Cost associated with bidding for a contract, do not satisfy the requirements of s. 2900(1)(c) because the bidding costs would have been incurred...
87 C.R. - Q. 27
Each employee's employment duties must be examined and a determination made as to whether his duties directly relate to the undertaking,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) | 21 |
IT-151R4 "Scientific Research and Experimental Development Expenditures"
Subsection 2900(4)
Administrative Policy
Prescribed Proxy Amount Policy 19 December 2012
The objective of the overall cap is to ensure that the total qualified SR&ED expenditures and PPA and other deductions specifically allowed under...
Subsection 2900(9)
Paragraph 2900(9)(c)
See Also
Oldcastle Building Products Canada Inc. v. The Queen, 2016 CCI 183
The taxpayer (“Oldcastle”), which was a leading producer of concrete building products, entered into an employment contract in 2004, with a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 2900 - Subsection 2900(9) - Paragraph 2900(9)(d) | percentage of net sales was not based on profits | 334 |
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) - Subparagraph 37(8)(a)(ii) - Clause 37(8)(a)(ii)(B) | sales-based comepensation nonetheless directly related to SR&ED | 422 |
Paragraph 2900(9)(d)
See Also
Oldcastle Building Products Canada Inc. v. The Queen, 2016 CCI 183
The taxpayer (“Oldcastle”), which was a leading producer of concrete building products, entered into an employment contract in 2004, with a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 2900 - Subsection 2900(9) - Paragraph 2900(9)(c) | sales-based remuneration was not bonus | 309 |
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) - Subparagraph 37(8)(a)(ii) - Clause 37(8)(a)(ii)(B) | sales-based comepensation nonetheless directly related to SR&ED | 422 |