One of the Scientific Research & Experimental Development (SR&ED) industry’s biggest gripes with the new T661(13) was the addition of “Part 9 – Claim preparer information.” This added section required that claimants and claim preparers provide sensitive information about their arrangement and the fees being charged for SR&ED assistance. SR&ED consultants argued this measure could allow exterior parties—such as accountants or auditors—access to confidential details about a firm’s payment structure and business model.
Seemingly in response to this, the Canada Revenue Agency (CRA) has added an alternative method of submitting Part 9 in an effort to address these issues: Part 9 can now be filed separately from the T661.
What is the new process for the T661(13) Part 9?
The CRA website describes the optional new filing process as follows:
- The claimant sends Form T661(13) to the CRA fully completed, except for Part 9 – Claim preparer information, by the reporting deadline.
- The claimant completes a paper copy of Part 9 for each claim preparer involved in preparing the SR&ED claim, and certifies that the information in Part 9 is complete and accurate.
- The claimant sends a cover letter that includes the claimant’s name, the claimant’s business number, and the tax year (start and end dates) of the claim, along with the paper copy of each completed Part 9, directly to their tax centre.
The change is a small but important one. Rather than including the required billing arrangement details within the T661, claimants now have the opportunity to send this information in separately if they so choose. This means that the sensitive particulars claim preparers are nervous about would go straight to the CRA, avoiding the possibility of claim auditors having access to the information.
This raises other potential issues, of course—mailing Part 9 separately could easily lead to a misplaced file and a $1,000 fine—but that the CRA has added this option means that, at the very least, they are monitoring the feedback on the new form.
The CRA has also added two new services: The SR&ED Self-Assessment Learning Tool and the First-Time Claimant Advisory Service. Join our LinkedIn group to be instantly updated when we cover these topics.
Do you think this policy update does enough to improve SR&ED Consultant Confidentiality? Join the conversation below or on LinkedIn.
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