Bruce Braithwaite's blog
Appellant is entitled to an investment tax credit in respect of the value of stock option benefits conferred by it on certain of
In a recently reported Tax Court of Canada case the court allowed a company to an investment tax credit in respect of stock options granted to employee that were involved in SR&ED work. The case Docket is 2003-748(IT)G Alcatel Canada Inc. vrs Her Majesty the Queen.
Manitoba budget increases SR&ED tax credit rate
In its 2005 budget Manitoba proposed to increase its R&D tax credit rate from 15% to 20% for expenditures made after March 8, 2005. The combined federal and provincial rate in Manitoba is now 48% for smaller businesses and 36% for other businesses. The 20% credit is only available to companies with a Manitoba tax liability. Credits unused in a year may be either renounced, or carried back or carried forward to be applied against Manitoba tax otherwise payable in the preceeding three or following seven taxation years.
Finance Minister Introduces Notice Of Ways and Means that proposes to change the definition of "in Canada"
Today the Minister of Finance issued a proposal to change the definition of “in Canada” with respect to expenditures made after February 22, 2005 on scientific research and experimental development carried on in Canada. If this legislation is passed into law, the expression “in Canada” will mean to include the exclusive economic zone of Canada as defined in the Oceans Act, including the airspace, seabed and subsoil in respect of that zone.
CRA issues new T661 form
Today CRA issued Revised Form T661: Claim for Scientific Research and Experimental Development (SR&ED) in Canada.
The form number is T661 E (04). A guide to the new form has also been issued. The guide, which is numbered T4088-04e, is effective February 9th, 2005. The previous guide T4088-03e is effective for claims filed on or before July 31st, 2005. Claims should now be filed on the new form.
CRA releases Application Policy SR&ED 2004-02: Filing Requirements for Claiming SR&ED Carried Out in Canada
CRA released this application policy to clarify its position regarding the filing requirements when administering the SR&ED legislation and Regulations. The bulletin addresses the requirements to use prescribed forms, and filing deadlines. Particularly helpful are policy statements on partnership filing requirements.
The document can be accessed by clicking on the link below.
Filing Requirements for Claiming SR&ED Carried Out in Canada
CRA releases pulp and paper sector guidance document
This guidance document addresses sector specific issues related to the SR&ED program as it pertains to the Pulp and Paper industry sector. It addresses the issues related to shop floor R&D occurring in the context of both commercial production and experimental production. A number of examples are provided in the document.
The document can be accessed by clicking on the link below.
SR&ED Chemicals Guidance Document #3 - Part I - Chemical Processes
Today CRA issued the Part I of Chemicals Guidance Document 3, entitled “Chemical Processes”. It provides an overview of the scope and context of different types of batch and continuous chemical manufacturing processes. Part 2, which will be issued next year, will deal with a series of continuous chemical processes.
Examples of the rules as they apply to batch and continuous processing are provided in the document.
The document can be accessed by clicking on the link below.
CRA releases guidance document on allocation of labour expenditures for SR&ED
Today CRA release a guidance document on allocation of labour expenditures for SR&ED. The following statement was included with the release:
CRA releases revisions to the SR&ED Plastics Materials, Processing, Equipment & Tool Making Guidance Document
In April 2004 CRA announced that The “Plastics Materials, Processing, Equipment & Tool Making” guidance document that deals mainly with issues that concern plastics processors was amended. Section 5 was added to deal with Mould Making (Equipment & Tool Making) issues.
CRA has also stated in this release that another section will be added at a later date to deal with Plastics scale-up, experimentation on commercial equipment work and pilot plants.


