When I was a very little boy, the very last bed-time story my Father would tell me went like this: “Once upon a time … the end”. That’s when I knew that I had reached the limits of his patience for telling stories (and putting off bed-time in the process). In a very real sense,…
DetailsIf you think about it, though, despite all of the flurry of activity around claim review process, policy and guidance documents, and so on … I haven’t yet heard about anything that represents a substantive change to the Income Tax Act (or regulations) and the real bones of the SR&ED program. If anything, there appears…
DetailsThe Canada Revenue Agency (CRA) has been releasing draft policy documents on the SR&ED Program for public comment over the past few months, as a part of an ongoing policy review exercise. They have done so at a time when the SR&ED Program is under intense scrutiny, the subject of two separate review exercises (The…
DetailsWhen the CRA traditionally takes on an adversarial role with claimants, it becomes easier for SR&ED consultants and their clients to feel encouraged when the Tax Court of Canada disagrees with a claim rejection, siding with the claimants who are making the appeal. However, we are still in the midst of an era where formal…
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DetailsVisit us at OCE Discovery 2017 – Look for Booth #706 (May 15/16, Metro Toronto Convention Centre, Toronto, Ontario)
Look for Booth #504 (May 9-10, 2016, Metro Toronto Convention Centre, Toronto
Visit us at Advanced Manufacturing Canada Conference & Exhibition – Look for Booth #200 (November 2-3, 2016, Toronto Congress Centre, Toronto, Ontario) Advanced Manufacturing Canada (AMC) offers the Canadian manufacturing community a two-day conference and exhibition focused on fostering a national dialogue about how manufacturers can leverage Advanced Manufacturing to stimulate innovation, increase productivity, and…
DetailsSRED Unlimited is an exhibitor at The Canadian Manufacturing Technology Show (CMTS-2017) that will take place in Mississauga, Ontario,September 25-28, 2017. CMTS-2017 is Canada’s national stage for manufacturing technologies, best practices and industry connections. http://cmts.ca/ Visit our booth #3620.
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DetailsIf you expect to claim SRED, CRA requires you to produce enough supporting evidence to justify the claim. Without such evidence, you may never get to discuss technical eligibility to any real extent. CRA will call the work “unsupported”, and simply close the file. Some time ago, I wrote a paper called The Myth of…
DetailsPerhaps you are familiar with the phrase “the sound of one hand clapping”. It’s all very mysterious and evocative. I’m not particularly mystical or meditative, but I’m going to use this phrase in a discussion of two opposite extremes in the preparation of an SR&ED claim. My thesis is simple — an SR&ED claim needs…
DetailsJust about any book or guide on Canada’s Scientific Research & Experimental Development (SR&ED) Program will include references to SR&ED-related court cases, if not an entire section. Does anybody read them? Really? Of course we do. Probably, most SR&ED practitioners spend some time studying court cases. (I make a personal hobby of it, including the…
DetailsOf course, no discussion of TA would be complete without talking about “novelty”. Novelty is what the Canada Revenue Agency (CRA) refers to when we make an argument that a certain chunk of work must be a technological advancement because that work entailed doing something that has never been done or attempted before. The first…
DetailsThe CRA will accept eye-witness testimony, from the key technical primes who were engaged in doing the work, even while they actively disapprove of the lack of better technical record-keeping. (Note that I say record-keeping, instead of “documentation” in this instance, because I would not want to mislead you into thinking that what CRA cares…
DetailsIn any larger organization, it can be difficult to sift through the complete list of projects and expenditures to arrive at potential SR&ED claims, assuming that you have the access and authority to do so. Even then, typically, you don’t have the resources to identify and claim everything. Maximizing the return on your efforts usually…
DetailsThe Five Somethings: Part 2 These five criteria were, to recap: (1) presence of risk or uncertainty, (2) hypotheses to reduce eliminate uncertainty, (3) scientific method (per 5-stage process), (4) pursuit of advancement, and (5) EVIDENCE Whether you are attempting to prepare your own SRED claims, or to assist your SRED Practitioner in helping you…
DetailsThe Five Somethings: Part 1 Until December 2012, there were three key criteria for SRED. Now there are five questions, plus a five-stage process … and one compound headache for taxpayers, who have to figure out what will be involved in complying with SRED requirements, going forward. Recent history: With their recently unveiled policy consolidation,…
DetailsMost projects fail to some degree. I think the documented percentage (per the Standish Group’s Chaos Report) is between 72% and 82%. Even if these percentages read like scare tactics to you, as they do to some people, it does not help to pretend that technical risks don’t exist, or need to be mitigated. Good,…
DetailsFrom an SR&ED perspective, project failure is useful. Failure for technical reasons is most useful. This is not to say that failure is “good”, in any sense – companies don’t appreciate failure, or reward it, usually. Most companies do not take failure as a sign of new learning, or in any constructive, positive sense. (I…
DetailsVariance 3 – Acknowledging or adjusting for the business context of the taxpayer contrasts sharply with the current trend, in which CRA reviewers are holding out definitions of advancement at the industry or technology level, regardless of business context. (Note: This will heavily penalize smaller firms, and effectively eliminates the notion of considering business context…
DetailsPart 1 of this article talked about some of the extra nuances and baggage that the Canada Revenue Agency (CRA) has recently begun adding to terminology that we use in the assessment and preparation of SR&ED claims, along with some of the implications (reduced claims). In this part, I’m going to examine one of the…
DetailsWhat technical means… to CRA What the CRA is teaching now is that the word “technical” refers generically to a domain of activity – technical content, technical issues, technical questions, and technical uncertainty – many of which are perhaps purely routine in nature. (Though, perhaps not, although CRA now tries to taint the word “technical”…
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