Tuna Temple Inc. v. Canada

Decided: 2026-10-21. Docket: A-23-26. Citation: 2026 FCA 175 (CanLII). Taxation — Income tax — Scientific research and experimental development — Income Tax Act — Whether thirteen projects qualify as “scientific research and experimental development” — Northwest Hydraulic Consultants Ltd. criteria applied, including hypothesis and systematic investigation — Findings of existing technology, trial-and-error, inadequate records, no knowledge gap — Appeal dismissed with costs | Procedure — Appeals — Standard of review and onus — Housen v. Nikolaisen — Whether the appellant met the initial onus to demolish the Minister’s factual assumptions — Hickman Motors Ltd. framework for refuting assumptions by prima facie evidence — No palpable and overriding error in Tax Court’s factual and mixed finding