The new COVID 19 wage subsidies will be considered “government assistance” for purposes of calculating eligible SR&ED expenditures.
While Vancouver and Toronto both have a rapidly growing and important tech sector, what has happened to Calgary? In 2019 Jason Kenney’s Alberta government introduced sweeping changes to a variety of incentive programs – introduced by the previous government – that were aimed at diversifying Alberta’s economy. Looking at Statistics Canada’s studies of these key […]
The 2019 Federal Budget removed the prior year’s taxable income as one of 2 factors used to determine the SR&ED (“scientific research & experimental development”) expenditure limit. All Canadian-controlled private corporations (aka “CCPCs”) are entitled to 35% refundable tax credits on their “SR&ED expenditure limit”. The SR&ED expenditure limit starts at $3 million and was […]
A little over a year ago my partner and I attended a meeting during which CRA’s Research Technology Advisor attempted to describe eligibility for the benefit of our client. He used the analogy of Columbus setting out for America in 1492. If that were being claimed today we would have to consider the claim in […]
As a former senior manager with one of the largest SR&ED practices in Canada, I remember that other tax practitioners referred to us disparagingly as part of the tax ‘compliance’ function. In the hierarchy of tax practitioners, tax compliance practitioners were considered somehow less ‘sexy’ than US & International Tax, Mergers & Acquisitions and some […]
As described in an earlier post, the Northwest Hydraulic case from 1998 resulted in a new set of criteria in order to determine the existence of SR&ED. The original 3 criteria were expanded into 5 Questions. The ORIGINAL 3 CRITERIA Scientific or technological uncertainty: Technological obstacles / uncertainties are the technological problems or unknowns that cannot […]
Of the estimated 20,000 claims for SR&ED submitted in 2017 (Source: Amy Siu – Pacific Region Assistant Director – SR&ED for CRA), fully 50% were for software, and at least 95% represented claims for “Experimental Development”. Presumably most of the eligible work was done by engineers using standard engineering techniques. Companies considering claiming SR&ED are […]