Ownership and Its Impact on SR&ED- CCPC versus Public-Owned or Foreign-Owned Corporations

In the recent case “Price Waterhouse Coopers Inc., agissant ès qualité de syndic à la faillite de Bioartificial Gel Technologies (BAGTECH) Inc. v. The Queen,” the Tax Court of Canada ruled in favour of Bagtech that it qualified as a Canadian-controlled Private Corporation (CCPC).  Even though more than 50% of Bagtech’s voting shares were owned by […]

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