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Eligibility of Software/IT Projects for SR&ED Richard Kun
Overview of SR&ED Eligibility ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
SR&ED Does NOT Include ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
Two Criteria for Project Eligibility ,[object Object],[object Object]
Technological Advancement ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
Examples of Possible Technological Advancement This could be the search for advancement in thermal modeling rather than strictly in computer science.  Further information should clarify whether the software development is being claimed (a) as SR&ED in computer science or information technology, or (b) as a support activity to another field of SR&ED.  "Customers required that our thermal modeling software provide more accurate estimates of the cooling requirements of micro-electronic components.  Our analysis indicated that a finite element (FE) approach to estimating heat transfer to the  cooling air might meet the requirements.  We implemented an FE model and tested its performance through simulations and bench experiments." The taxpayer had to intervene in the technology and conduct experimentation to advance the processing in a complex system. "Through experimentation, we developed a set of methods for bridging multiple teleprocessing monitors and database management system environments while ensuring data synchronization. Developing new algorithms in the |attempt to achieve required performance indicates that the work was performed for the purpose of technological advancement, whether or not the software actually gave the desired performance. "We researched possible image compression approaches without identifying an obvious solution  to our requirements.  We then developed, tested, and discarded various compression algorithms in an effort to find one that would meet our required specifications." This is an indication that the taxpayer may have made an advance in computer science or information technology.  "We developed a new approach to perform text searches in large distributed data bases."  Comments Example
Examples of No Technological Advancement On review of the claim, it was found that the development was achieved using commercially available application programming tools supplied in third-party software products.  In contrast to the thermal modelling example above, this application (computer-aided instruction) is an ineligible area, i.e., social sciences or humanities.  Therefore, in order to be eligible, the software development work would have to be SR&ED in computer science or information technology, and cannot be merely a supporting activity.   "We developed a new software system for computer-aided  instruction embodying innovative object-oriented programming concepts and operating on a heterogeneous RISC workstation/ personal computer network."  The taxpayer wrote a tape driver program operating under UNIX.  This was routine software development for a programmer experienced in the UNIX environment.   "We developed a new means to transfer data from the mainframe computer to the UNIX system via a 9-track tape drive.”   The use of existing technology and learning about its capabilities, even in a complex computing environment, are not technological advances.   "The new operating system represented technological advancement to the company as its time-sharing capabilities were far more advanced than those of the operating system with which we were familiar.  The project also significantly advanced our understanding of relational database technology applied to commercial applications."   This is an improved product feature.  As presented, there is no indication of any technological advance.  Statements such as the third sentence add no substance and should be avoided SR&ED project descriptions.  If there is a technological advancement, it should be specifically described. "Version 5 of our retail store management software provided automatic invoice generation for corporate clients at the end of each month. This included new algorithms for the calculation of various applicable taxes. This was a new capability that meant that  our software was technologically the most advanced available.“ Comments Example
Technological Uncertainty ,[object Object],[object Object],[object Object],[object Object],[object Object]
Examples of Possible Technological Uncertainty Since the success rate of human experts is given as a benchmark, the uncertainty is in computer science rather than in the application domain.  The SR&ED project description  expanded on the specific sources of uncertainty in information processing. "As a developer of expert system tools, we did not know whether the proposed logical architecture of our latest inference engine would give an increase in correct  decision-making when measured against human experts in the target application domain."   Given the state of software technology at the time the work was performed, this problem represented an uncertainty regarding which, if any, technological solution would succeed.   "Our system architecture was moving towards distributed databases and distributed processing. Viable directory services for locating distributed data in a network like ours with thousands of servers, were not available. It was uncertain how to proceed to overcome this."   The Technological Uncertainty was created by the unavailability of third party proprietary information. "The manufacturer of the software product that we wanted to integrate into our own would not divulge the method by which it handled inter-process communication. It was unclear how we could interface the two programs."  The claimant was a relational database management system (RDBMS) vendor. The Technological Uncertainty was created by the need for the company to push its technology beyond existing limits in order to meet opposing demands for the database integrity and speed. "The problem was how to meet the required numerical specifications for a high-volume, interactive, distributed database.  Our existing technology for multi-phase commit and record-lock synchronization would not allow us to meet real-time, on-line data availability specifications."  Comments Example
Examples of No Technological Uncertainty The problem described is not a Technological Uncertainty. If there is any SR&ED in association with the system redesign, the specific technological problem must be stated. "The system had been designed on the assumption that orders would be filled in the same order that they were received. We were uncertain how to redesign it to process orders in a random sequence."  As described, this is a business risk. The description also suggests that, if there are Technological Uncertainties, they are borne by the supplier, not by the claimant. "Our company selects new technologies based on planned and advertised features and performance specifications. Each time this is  done, we face the uncertainty of whether the supplier can deliver the enhanced technology and, if so, according to planned time frames.“ Although complex, in this case the problem was amenable to standard software development techniques applied by competent professionals possessing sufficient skill in software development and mathematics. The second sentence is insufficient to indicate Technological Uncertainty. "We were not sure if we could develop a program to calculate the highly complex financial data required. We had never done this before and we were not aware that any such system had been developed." This is an uncertainty in how a business process will be affected by the introduction of a technology.  It is not a technological uncertainty. "Since this was a new system, the nature of the user queries could not be predicted and this created uncertainty as to which design was feasible." Comments Example
Examples of Frequently Eligible Projects ,[object Object],[object Object],[object Object],[object Object],[object Object]
Examples of Frequently Ineligible Projects ,[object Object],[object Object],[object Object],[object Object]
Eligible Project Activities ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]

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Rdp Software & IT Eligibility

  • 1. Eligibility of Software/IT Projects for SR&ED Richard Kun
  • 2.
  • 3.
  • 4.
  • 5.
  • 6. Examples of Possible Technological Advancement This could be the search for advancement in thermal modeling rather than strictly in computer science. Further information should clarify whether the software development is being claimed (a) as SR&ED in computer science or information technology, or (b) as a support activity to another field of SR&ED. "Customers required that our thermal modeling software provide more accurate estimates of the cooling requirements of micro-electronic components. Our analysis indicated that a finite element (FE) approach to estimating heat transfer to the cooling air might meet the requirements. We implemented an FE model and tested its performance through simulations and bench experiments." The taxpayer had to intervene in the technology and conduct experimentation to advance the processing in a complex system. "Through experimentation, we developed a set of methods for bridging multiple teleprocessing monitors and database management system environments while ensuring data synchronization. Developing new algorithms in the |attempt to achieve required performance indicates that the work was performed for the purpose of technological advancement, whether or not the software actually gave the desired performance. "We researched possible image compression approaches without identifying an obvious solution to our requirements. We then developed, tested, and discarded various compression algorithms in an effort to find one that would meet our required specifications." This is an indication that the taxpayer may have made an advance in computer science or information technology. "We developed a new approach to perform text searches in large distributed data bases." Comments Example
  • 7. Examples of No Technological Advancement On review of the claim, it was found that the development was achieved using commercially available application programming tools supplied in third-party software products. In contrast to the thermal modelling example above, this application (computer-aided instruction) is an ineligible area, i.e., social sciences or humanities. Therefore, in order to be eligible, the software development work would have to be SR&ED in computer science or information technology, and cannot be merely a supporting activity. "We developed a new software system for computer-aided instruction embodying innovative object-oriented programming concepts and operating on a heterogeneous RISC workstation/ personal computer network." The taxpayer wrote a tape driver program operating under UNIX. This was routine software development for a programmer experienced in the UNIX environment. "We developed a new means to transfer data from the mainframe computer to the UNIX system via a 9-track tape drive.” The use of existing technology and learning about its capabilities, even in a complex computing environment, are not technological advances. "The new operating system represented technological advancement to the company as its time-sharing capabilities were far more advanced than those of the operating system with which we were familiar. The project also significantly advanced our understanding of relational database technology applied to commercial applications." This is an improved product feature. As presented, there is no indication of any technological advance. Statements such as the third sentence add no substance and should be avoided SR&ED project descriptions. If there is a technological advancement, it should be specifically described. "Version 5 of our retail store management software provided automatic invoice generation for corporate clients at the end of each month. This included new algorithms for the calculation of various applicable taxes. This was a new capability that meant that our software was technologically the most advanced available.“ Comments Example
  • 8.
  • 9. Examples of Possible Technological Uncertainty Since the success rate of human experts is given as a benchmark, the uncertainty is in computer science rather than in the application domain. The SR&ED project description expanded on the specific sources of uncertainty in information processing. "As a developer of expert system tools, we did not know whether the proposed logical architecture of our latest inference engine would give an increase in correct decision-making when measured against human experts in the target application domain." Given the state of software technology at the time the work was performed, this problem represented an uncertainty regarding which, if any, technological solution would succeed. "Our system architecture was moving towards distributed databases and distributed processing. Viable directory services for locating distributed data in a network like ours with thousands of servers, were not available. It was uncertain how to proceed to overcome this." The Technological Uncertainty was created by the unavailability of third party proprietary information. "The manufacturer of the software product that we wanted to integrate into our own would not divulge the method by which it handled inter-process communication. It was unclear how we could interface the two programs." The claimant was a relational database management system (RDBMS) vendor. The Technological Uncertainty was created by the need for the company to push its technology beyond existing limits in order to meet opposing demands for the database integrity and speed. "The problem was how to meet the required numerical specifications for a high-volume, interactive, distributed database. Our existing technology for multi-phase commit and record-lock synchronization would not allow us to meet real-time, on-line data availability specifications." Comments Example
  • 10. Examples of No Technological Uncertainty The problem described is not a Technological Uncertainty. If there is any SR&ED in association with the system redesign, the specific technological problem must be stated. "The system had been designed on the assumption that orders would be filled in the same order that they were received. We were uncertain how to redesign it to process orders in a random sequence." As described, this is a business risk. The description also suggests that, if there are Technological Uncertainties, they are borne by the supplier, not by the claimant. "Our company selects new technologies based on planned and advertised features and performance specifications. Each time this is done, we face the uncertainty of whether the supplier can deliver the enhanced technology and, if so, according to planned time frames.“ Although complex, in this case the problem was amenable to standard software development techniques applied by competent professionals possessing sufficient skill in software development and mathematics. The second sentence is insufficient to indicate Technological Uncertainty. "We were not sure if we could develop a program to calculate the highly complex financial data required. We had never done this before and we were not aware that any such system had been developed." This is an uncertainty in how a business process will be affected by the introduction of a technology. It is not a technological uncertainty. "Since this was a new system, the nature of the user queries could not be predicted and this created uncertainty as to which design was feasible." Comments Example
  • 11.
  • 12.
  • 13.

Notas del editor

  1. A Technological Advance is the discovery by the company of technical knowledge that advances the understanding of information technology or computer science. It is the attempt to achieve Technological Advancement that is important in determining eligibility. A failure can increase knowledge of information technology or computer science by showing that a particular technological approach will not succeed. The implementation of existing technology in the company is not evidence of Technological Advancement. For example, implementing a state- of-the-art computer system does not qualify; it is only the experimental development of technology that is relevant to eligibility. The company must be able to identify the new software construct(s), architecture, or technique(s) sought or developed within the R&D project that advances this understanding of information technology or computer science. Technological Advancement is typically made through innovations in software architectures, designs, algorithms, techniques or constructs. Credible support for these advances includes comparing them against what was previously available (e.g. based on third-party literature).
  2. Technological Uncertainty arises when the solution, or the method of arriving at the solution, is not readily apparent to appropriately skilled and experienced software developers after they have analyzed the problem using generally known software development techniques. It must be identified when an R&D project is initiated. The company must be able to show that there was a fundamental problem with the technologies that had to be addressed. That is, there was at least a.                   one issue that raised a doubt as to whether the specification could be met within the technical constraints (not marketing, or other such constraints), or b.                  one design issue or design alternative that had to be resolved through recorded investigation, analysis and/or prototype coding (but not through discussion alone).