At long last, the release of Phase 6 final policy document is completed. Here are the newly updated SR&ED policy documents, ready for your review.
As a result of the consolidated public consultation conducted by the CRA from 2010-2012, the updated SR&ED policy review was released on Wednesday, December 19th and can be accessed via the CRA website.
After the Government of Canada tasked the Canada Revenue Agency (CRA) with improving the administration of the SR&ED program, including conducting a comprehensive review of SR&ED policies and procedures, the CRA implemented an SR&ED Policy Review Project. The CRA is pleased to announce the successful completion of this project and to release new, consolidated SR&ED policy documents.
A Complete Overhaul of SR&ED Documents
It’s not often we can definitively say the CRA has gotten something right. Under the guidance of Helene Marquis, this project has come a long ways since the consultations almost a year ago. When the draft documents were initially released, they were just that – drafts, in need of considerable revision. The final policy documents, listed below, reflect the careful consideration of the department and consultations regarding alignment with current legislation and jurisprudence.
Don’t take our word for it. Below are the links to the updated policy documents:
- SR&ED Policy Review Project – December 2012 Update – Explains the changes of the program. It’s worth starting with this link.
- A brief history of the definition of SR&ED and A brief history of the guidance on the eligibility of work – Provide background on the program, but without the messy details of politics.
- Eligibility of Work for SR&ED Investment Tax Credits Policy
- SR&ED Glossary
- Assistance and Contract Payments Policy
- Contract Expenditures for SR&ED Performed on Behalf of a Claimant Policy
- Materials for SR&ED Policy
- Pool of Deductible SR&ED Expenditures Policy
- Prescribed Proxy Amount Policy
- Recapture of SR&ED Investment Tax Credit Policy
- SR&ED Capital Expenditures Policy
- SR&ED Claims for Partnerships Policy
- SR&ED During Production Runs Policy
- SR&ED Filing Requirements Policy
- SR&ED Investment Tax Credit Policy
- SR&ED Lease Expenditures Policy
- SR&ED Overhead and Other Expenditures Policy
- SR&ED Salary or Wages Policy
- SR&ED Shared-Use-Equipment Policy
- SR&ED while Developing an Asset Policy
- Third-Party Payments Policy
- Total Qualified SR&ED Expenditures for Investment Tax Credit Purposes Policy
- Traditional and Proxy Methods Policy
Highlights: Eligibility Document & SR&ED Glossary
Easily the two best links are Eligibility of Work for SR&ED Investment Tax Credits Policy and SR&ED Glossary. The two documents are inter-related – while reading through the eligibility document, it’s possible to click on any key term and have it go directly to that term in the glossary. The definitions in the glossary as also very well done, showing where SR&ED work likely ends and routine development begins, along with common exceptions (often leaning towards eligibility).
Summary: A Great Start – Will It Continue?
At long last, it’s a clear explanation of the SR&ED program, with clear questions based on jurisprudence. While the CRA SR&ED Policy department has done an exceptional job with the launch of this, it remains to be seen whether the administration reflects the positive outlook of headquarters. The gap between politics, policy, and administration have been quite wide over the last few years. At SREDucation, we’ll be watching to see if this new direction is accurately reflected in taxpayer interactions with the CRA. Our fingers are crossed.