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Scitax Advisory Partners

Submission — Scitax Advisory Partners

Important note: The content of submissions and summaries is the sole responsibility of the person and / or organization having made a submission. The posting of this content does not indicate that the Panel supports or endorses it. Submissions and summaries are posted in the language provided without modification.

Submitter(s): Cadesky, Michael; Hearn, David

Summary: Our submission to you is focused exclusively on questions 9 and 10 of your consultation, i.e. SR&ED. In summary our view is that the existing legislation gives Canada what amounts to the world's best R&D tax incentive for private corporations and certainly near the very top of this list for public corporations as well. We see no reason to change the existing SR&ED benefit mechanisms except perhaps to offer some way for non-CCPCs to more readily monetize their benefits. However — based on our experience — there remains great room for improvement in how the SR&ED program is delivered and administrated by CRA. Despite the various initiatives CRA has recently undertaken to improve its delivery of the SR&ED program, we continue to see the efforts of too many of Canada's genuine SR&ED performers unduly constrained by SR&ED assessment rulings which are badly flawed and inconsistent. At the same time we see too many frivolous SR&ED claims allowed simply because they are too small to justify the allocation of sufficient resources to make an adequate review.

Full submission: PDF Version