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Siena College, Loudonville ​kara what those of you haven't met my name is Gabe Sabrina um I'm at essar needy and tax practitioner from the Burlington area I guess I've been involved in the clean processing so I'm 1993 I'm not charted accountant by training but a lot of the work that I do will be on technology side as well with with engineering teams that I work with today what we've done for the tail end is we've taken a lot of the information that you've talked about the last couple days how did this decide what an eligible project is how to document it and then apply those principles to income tax court legislation and precedents so what we're going to do is we're going to we're through issues on a technology side whether companies qualified and why or why not and look at what the clit said both were the taxpayer one and we have a taxpayer lost and what we can learn from that how we can apply that to our situations and we're going to do the exact same thing for financial issues we're going to go through all the areas of cost wages material subcontractors overhead other issues that affect credits such as ccpc status and we'll talk about what we call the black and white and in the gray areas so a lot of times things are black and white you go to court and judges hey this is clear nice clear judgment but very very often they say well this isn't so clear this is an issue that's ambiguous or requires application of judgment and that's where all the opportunities start to pop out and where if you understand the principles you can maximum this keeps on Northwest hydraulic consultants it's probably one of the landmark cases are in technical technological eligibility what happened here as we had to university professors that were engineers and PhDs and are you being weird leaders are what they did and basically the argument that the CLA made is you guys are so smart that nothing could ever create a problem for you you know everything there possibly is to know about engineering of aquatic devices and they go on to say that you know we have a really ambitious scheme but all were described with project refers to standard devices and processes which are routinely used in similar to ensign situations around the world so they're going back to a technological and certainly part and saying that combining standard technologies and devices is eligible if non-trivial combinations of these devices carry uncertainty so they're admitting another device here we're using radio roles of solutions and dams and rubber dams and all kinds of different devices but they're saying it's the combination of those much like a chess game sure we know all the pieces move that's the particular combination was presented water order that can make the difference between winning and losing the match here ok so the courts come in the mail system just as the respondents position that's been the CAE is it be articulated by mr. rack Gasca which the Syria reviewer was essentially the pilot the appellant committee the world leader in the field of hydraulic model testing by its own excellence that's a standard for what presents routine engineering or stay the practice in other words they know everything that there is to know nothing that they do have involved in the uncertainty because they're just so clever nose on say with respect to this I think this is an unrealistically high standard and deed a standard of perfection that we just could just certainly be in Canada ok so then he goes on to look at five over seventeen projects in question and reels that the four largest are in and more in particular that the largest of those was exemplary van lesson to do project so exemplary he could not understand how the Syria could ever have questioned it in the first place and actually make some comments that they should reevaluate their circulars and we look at how they're doing stuff so one is a river diversion dam and what the client says is that the uncertainty and aided investigation looked at the optimal combination of viewers with your dates and was a very different types sizes materials whatnot so each of those would be available and as we said every time we add a new variable the project goes geometrically stronger the judge looked at this and admitted that these guys are world leaders or what they did and yet they did he get it on the first try as a serious a nurse routine they actually experimented they looked at all different options and then physically prototype three of those to compare them just saying like if you need the right answer was why would you look at five alternatives and prototype three of them you would just install the right answer then collect the money from the client and could make more money would with all kinds of experimentation and waste your clients money so again they said if he whipped it really different principles but yes would apply in a different scenario so they talked about the riverbed here how it was different how it was an easel model how it had different regular reason it how am i different flow rates how the river was no existing model anywhere in the world that will allow them to do this without this experimentation and the judge agreed so they identify the variables and we should work directly related to evaluating those variables are making a conclusion why in this particular situation one was better the weather and the Syrian was unable to show that there was any definitive answer on how to do this ahead of time so of course I wasn't okay so the client one and the judge commented again it should
move a little bit in court on that even though very small one and I don't even know why the judge kick this one out I thought all five projects are actually fairly strong but we want them to kick out the smallest 1i think more just to give the CLA something for cure right so we've talked about a sediment study to devise a solution to decrease sediment deposits for a particular area and they analyzed three alternatives here flushing bed pioneer stemma peninsula nothing in the video final answer that will be apparent as using standard techniques now this is one of the ones where i can kind of see where the judge is coming from and in the principles apply a lot in current judgments which is and which is the argument seriously successful lake that you didn't try to combine you didn't try to combine different methods for look at different methods and oils limitations of any one of them and then maybe use ideas from another method to improve that you looked at three or four different methods pick method to and used it and it worked okay now that's that's a very dangerous position if it looks like that's what's happing your project silly and the course are likely so that's just a market research that's finding the squirrel ran the existing state of practice was at the start and using that method and so it's more often when you're saying none of those methods actually works perfectly here the shortcomings but we have ideas on how to make that method better that you would have a knowledgeable project right so I get Northwest hydraulics all of these cases you can download from tax credit canada website girlfri the public information so what I tend to do is pick cases that correspond to my clients industry situations facts or whatever show them exactly what the court said rye and allow them to not that to their fact situation so if we have a similar fact situation we can argue we should have a similar treatment okay so as I said Northwest hydraulics probably landmark case on technological eligibility and since they came out we were 10 years ago it's been cited in pretty much every other case on technological Alex but they're always going to keep referring back to that case so just before we go on to ring the pipeline the closing remarks I like on my hydraulics because it's such an important case the judge recognizing commenter legal legal implications the income tax that definition of experimental development he also referred to the French wording of the legislation to clarify any ambiguity which he found might be found in the words including incremental improvements there too so the quartz take this including incremental improvements into very seriously says in addition to these woods in 1995 appear stood in response to the concern that achievement attempted that achievement or attempted achievement of slight improvements was not covered he goes on say I should not have father is necessary to say so most scientific research involves gradual include info testimony small progress spectacular breakthroughs are were rare and make a very smart of the result very small part of the results of SME be in Canada so again we don't have to be ten percent better than we were before you can be effective one percent better as your objective as long as involves technological insert okay wait a minute i prime where you go pipelines an interesting one where the client identifies about 140 different areas where they're looking at a pipeline and they have a contract to maintain this pipeline I've been Piper Alberta and they spend about four million bottles let's say on it two million of which they claim as s on you do expenses and the sear it comes back and says wonder this you're just trying to find out the problems as part of your routine engineering or routine maintenance contract since you're getting paid for us there appears to be no technological advancement and again this seems to be a bit of a mindset that if you're doing it for free it's good but if someone's paying you to do it that can't be any technological advancement in there it must be commercial always laugh at that and I say well it shouldn't aside strive to claim not whether someone's paying me so what do you mean by that I said well if you offered me a billion dollars to build you a time machine are you saying because I'm getting two billion dollars there's no uncertainty any more of it Billy a time machine is very simple now of course not but that's the whole point getting paid for something fact the finally repay me for something because the probably is a problem especially where they pay me must be a big problem where you wouldn't pay me so much to do it ok so the sale of experimental collection will talk about that it's completely irrelevant I was being paid under it so what happens here is they're saying about all of this work that we're doing is we can stand a practice for industry and they go out into so not really that have third-party evidence by the national energy board and anyone the time that they doing it but they say why Solange boy had an injured inquiry into stress corrosion on Canadian oil gas pipelines the company was invited to participate on the way the study and concluded that you know they didn't know the cause of the pipeline ruptures and they'll then go on to talk about coming up CPR and age is called sepa community mg pipeline Association whose members agreed that the they identify these problems so the client came into court and had very convincing evidence of experts that these way industry problems that everyone agreed had no working solution and need to be investigated judge put a lot of emphasis on that okay so basically what happened is the client came up with a whole bunch of issues that the judge thought was very strong evidence of us are needy work so the areas of uncertainty or departures from standard practice and things caused by the purchase were saying the practices would cause the stress corrosion cracking because at the forum what caused it to grow what were the factors available so we know some of them but you don't know all of them and the industries that we're dealing with
our members of agreed that we don't all of them have written papers on what we know and don't know so there's a lot of credible evidence of licking standard practice or nature of a science was they talked about what parameters caused the formation the initiation and the growth and we're different for the right here with a nonlinear how would they work how to control the growth rates how do predictor so all of those things the judge said those are very that the evidence that the client provided of other industry associations who looked at similar studies and concluded that they didn't have the answer for strong evidence that the client took reasonable steps to do this and ultimately the clay was unsuccessful they were unable to determine a lot of the causes so the judge says the rejection after testing a hypothesis is level s in advance often it's the activities that fail commercially that are stronger evidence of Technology uncertainty we are giving a waste hundred-dollar 0 company's money to do something didn't work unless a either thought it would work or maybe you thought it might not work but you still wanted to understand why either way it's a voice the flavors are very strong indicators of us are need that are proof but again the courts are going to smile on those to say if you're analyzing alternatives instead of going right to the front man sir it's probably because you wanted to understand why something was happening okay so another great case where the taxpayer one see them agencies here's one where the taxpayer losses so in this case it's kind of an older case on software going back to the 1998 and maybe what we talked about Union Theological Seminary, Morningside Heights (Columbia University area).
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