Robotx Solutions Inc. 2017 TCC 73

The takeaway?

NOT ALL UNCERTAINTIES ARE TECHNOLOGICAL UNCERTAINTIES

Note that emphasis was placed on these words:

  1. improve
  2. optimize
  3. minimize

Even though the Income Tax Act specifically says:

“for the purpose of creating new, or improving existing, materials, devices, products or processes, including incremental improvements thereto” – Subsection 248(1) the definition of Scientific Research and Experimental Development