SR&ED Technical Narratives: The Truth About Word Limits
Updated to Reflect New Policies (2022)*** Some of the policies referenced were updated 2021-08-13. This article has been updated and is accurate as of 2022. *** |
Does your SR&ED technical narrative fit into the T661 “frame”?
Part 2, Project Information of the T661 form contains a “technical narrative” portion, which serves as a blueprint of the Scientific Research and Experimental Development (SR&ED) work performed by the claimant(s). This narrative is an extremely important section of an SR&ED claim; it must succinctly summarize months of SR&ED work and prove the eligibility of the work performed.
However, there is still some confusion around the absoluteness of the word limit placed on technical narratives. In fact, some claimants are concerned that CRA review software may truncate (i.e. cut off any words or characters after a character limit is reached) technical narratives.
This article will attempt to break down the confusion and offer some useful suggestions to help overcome any potential issues regarding the length of technical narratives.
Length Limits: Expectation vs. Reality
The length limitations for each subsection of Part 2 of the T661 1 ‘Section B – Project Descriptions’ are as follows:
Line 242 What scientific or technological uncertainties did you attempt to overcome?
(Maximum 350 words)
Line 244 What work did you perform in the tax year to overcome the scientific or technological uncertainties described in line 242?
(Maximum 700 words)
Line 246 What scientific or technological advancements did you achieve as a result of the work described in Line 244?
(Maximum 350 words) 2
Simple math (350 + 700 + 350) shows that claimants should have a maximum of 1 400 words for their technical narrative. However, several issues can impact the interpretation of what exactly constitutes one “word”
So… What’s in a Word?
Technology is an imperfect beast. Inconsistencies between your tax preparation software of choice and the CRA‘s claim review software can mean the difference between a 1 350 passage of text and a 1 423 passage of text. Here are some key issues that can arise:
- Approximation — Different tax preparation programs (TurboTax, TaxPrep, etc.) can often only approximate character limits for various tax claim subsections;
- Units of Measurement — Tax prep programs calculate length differently. Some count individual words, whereas some count lines.
- Hyphens and spaces and symbols… Oh my! — Hyphenated words, spaces between words, and special symbols (# / & / * / @, etc.) may be given different “values” by CRA review software and by your tax prep software.
So what’s an SR&ED claimant to do?
Avoid Simple Pitfalls
There are a few simple things to keep in mind to help ensure that the technical narrative you write is the same one that gets read by the Canada Revenue Agency (CRA):
- Make sure that your tax prep software takes every character space into account. CRA review software treats blank spaces and blank lines (i.e. empty lines between paragraphs) as part of the total character count.
- Be cautious with formatting — indentations or italicized text can show up unpredictably in CRA review software.
- Leave some room for interpretation. Don’t write a technical narrative with the exact number of words/characters allowed for each line item. Stay close to, but ideally under, the length requirement.
- Don’t save the best for last. As a safeguard, avoid placing vital information at the very end of your narrative. The strength of your claim may be compromised if the text gets truncated upon review.
- Read our top 3 hints for writing SR&ED narratives.
This article is based on CRA policy documents available at the date of publication. Please consult the CRA website for the most recent versions of these documents.
a) different software packages have different intricate limits = test the software before wasting time “word-smithing”. For instance, two short words are often better than one long word.
b) For simplicity, the CRA, and SRED writers alike, often use cliche statements that don’t clearly communicate the Law of what constitutes SRED. Thus, it’s all too easy to mistakenly discount legitimate SRED claims because innovation and creativity is difficult to form the right perspective – especially to show the planned sequence of experimenting in overall approaches is NOT substantially set prior to experimenting. Thus I suggest that the most important skill a writer needs is to be able to relate the high level advancements in design approach beyond known practice for what sometimes appears as necessary incremental detailed minutia (aka. routine) testing. Thus the investigation needs to be framed with the appropriate SRED perspective.
Mark, you bring up some good points.
Re a) I completely agree. Not all software is created equal.
Re b) I personally believe that the shift to the short form was the wrong one. While it appears to be “less paperwork” for the taxpayer, the result is that the taxpayer cannot clearly establish their technology base and the CRA needs to come out to review. More reviews = more paperwork. It’s difficult to communicate the Law of what constitutes SRED when you’re worried about such tight word counts.