Evidence, What Evidence?

Recent anecdotal evidence suggests that the Canada Revenue Agency (CRA) is becoming increasingly detailed (and according to some, who disagree with them, occasionally irrational and unreasonable), in its approach to supporting documentation. This is news? Certain newspapers or columnists continue to create stories about the fact that reports are going to be published, by various…

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Moving Beyond “Claim Prep”

As SR&ED Consultants, we owe a duty to our clients to help them develop new capabilities and acquire new knowledge.  I think we need to move beyond simple claim preparation into “process development” and even “training”. Personally, I take on that obligation as a fundamental part of the consultant’s role. In case you hadn’t noticed,…

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Technical vs. Technological: what the CRA is saying: Part 2 (continued)

Variance 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…

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Technical vs. Technological: what the CRA is saying: Part 1 (continued)

What 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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Let the games begin

There’s nothing quite like the scent of money to bring out the corporate games players and political opportunists, but if a company isn’t careful, these games players can foul up a perfectly sound SR&ED program.  Unfortunately, the very nature of the SR&ED program makes this scenario more possible. One phenomenon that seems to be unique…

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Before you buy

Satisfying the negative test of intention You may well feel that it’s nearly impossible to try to prove that you did not intend to do a given thing at any point in time.  However, this doesn’t have to be as tricky as it seems. The reason for this question is that, under the SR&ED program,…

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