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Technical Management Consultants Inc. Submission in Response to Joint Finance Canada Canada Revenue Agency Consultation Improving the Scientific Research and Experimental Development Tax Incentives:

November 5, 2007

Nancy Horsman and Peter C. Armstrong
Joint Finance Canada – Canada Revenue Agency SR&ED Consultations
140 O'Connor Street
L'Esplanade Laurier
Ottawa, Ontario
K1A 0G5

Dear Sir/Madamme;

I am writing on behalf of Technical Management Consultants Inc. We thank you for the opportunity to take part in the initiative to improve the Scientific Research and Experimental Development tax incentive program. We are submitting the following as our proposal on improvements that we feel should be implemented to improve the effectiveness of the program. I give you permission to post my comments on your website.

  • Provide a portion of refundable ITC's for clients who are now considered non refundable due to ownership structure (ie. non CCPC, proprietorship) or taxable income level.
  • Provide consistent, extensive training for CRA reviewers to ensure the program is administered in a consistent, effective manner in all regions.
  • Reintroduce partnership committees involving representatives from industry and government for the purposes of formulating concise application policy papers and guidance documents.

Thank you the opportunity to give our input. We look forward to working with you in your efforts to improve the administration of this vital program.

Sincerely;

Al Gordon
Technical Consultant
Technical Management Consultants Inc.
1608 Sylvestre Drive, Unit 1
Tecumseh, Ontario
N8N 2L9

al@tmci.com