Canada: Sources

This page lists every source cited across the Canada pages, starting from the Canada overview. Each entry gives the title, the publisher and the provisions or sections the pages rely on. Legislation is linked to the consolidated text on the Justice Laws website. CRA material is linked to canada.ca. All sources were accessed on 11 October 2026. Where a page relies on a source for a specific point, the page itself carries a numbered citation.

Legislation

• Income Tax Act, RSC 1985, c 1 (5th Supp), section 37. Government of Canada, Justice Laws website. Subsections 37(1), (11), (11.1) and (12): the SR&ED deduction, the prescribed form, its filing deadline and the consequences of missing information or a late form.
• Income Tax Act, section 127. Government of Canada, Justice Laws website. Subsection 127(9), definition of "investment tax credit", paragraph (m).
• Income Tax Act, section 152. Government of Canada, Justice Laws website. Subsections 152(3.1) and (4): the normal reassessment period and assessments of tax, interest and penalties.
• Income Tax Act, section 162. Government of Canada, Justice Laws website. Subsections 162(5.1), (5.2) and (5.3): the claim preparer information penalty, the due diligence defense and the definitions of "claim preparer", "claim preparer information" and "SR&ED form".
• Income Tax Act, section 163. Government of Canada, Justice Laws website. Subsection 163(2), the gross negligence penalty, including paragraph (d), and subsection 163(3), the burden of proof.
• Income Tax Act, section 163.2. Government of Canada, Justice Laws website. Subsection 163.2(1) definitions and subsections 163.2(2) to (6), (9) and (14): the third party penalties.
• Income Tax Act, section 165. Government of Canada, Justice Laws website. Subsections 165(1), (1.11) and (3): the notice of objection, large corporations and reconsideration by the Minister.
• Income Tax Act, section 166.1. Government of Canada, Justice Laws website. Subsections 166.1(1), (2) and (7): extension of time to object.
• Income Tax Act, section 169. Government of Canada, Justice Laws website. Subsection 169(1): appeal to the Tax Court of Canada.
• Income Tax Act, section 220. Government of Canada, Justice Laws website. Subsection 220(3.1): waiver or cancellation of penalties and interest.
• Income Tax Act, section 230. Government of Canada, Justice Laws website. Subsections 230(1) and (4): records and books of account and the retention period.
• Income Tax Act, section 231.1. Government of Canada, Justice Laws website. Subsections 231.1(1) and (3): inspection, audit and examination powers.
• Income Tax Act, section 239. Government of Canada, Justice Laws website. Subsections 239(1.1) and (2): offences relating to refunds and credits.
• Income Tax Act, section 248. Government of Canada, Justice Laws website. Subsection 248(1), definition of "scientific research and experimental development".
• Tax Court of Canada Act, RSC 1985, c T-2, section 18. Government of Canada, Justice Laws website. Subsection 18(1): the informal procedure for income tax appeals.
• Tax Court of Canada Act, section 18.12. Government of Canada, Justice Laws website. Order for the general procedure and the election to limit amounts in issue.

CRA forms and guides

• Form T661, Scientific Research and Experimental Development (SR&ED) Expenditures Claim, T661 E (26). Canada Revenue Agency. Page 1; Part 2 (lines 200 to 282); Part 8, Claim checklist; Part 9, Claim preparer information (lines 935 to 975 and billing arrangement codes); Part 10, Certification (lines 165 to 175); privacy notice.
• T4088, Guide to Form T661, T4088(E) Rev. 20. Canada Revenue Agency. Sections on the SR&ED reporting deadline, filing requirements, Part 2, Part 9 (including the worked example of a contingency fee) and Part 10.
• Form T1322, Application for Scientific Research and Experimental Development (SR&ED) pre-claim approval. Canada Revenue Agency. Parts 1 to 3 (lines 010 to 082), including Section C, who prepared the responses.
• The SR&ED Review Process: A Guide for Claimants (April 20, 2026). Canada Revenue Agency. Sections on selection for review, withdrawal, who conducts reviews, Steps 1 to 3, the dispute resolution process, pre-claim approval and Appendix A.
• P148, Resolving your dispute: Objection and appeal rights under the Income Tax Act, P148(E) Rev. 25. Canada Revenue Agency. Sections on time limits, the objection review, collection of disputed amounts, extensions and appeals.
• SR&ED Pre-claim approval, information sheet, Cat. Rv4-224/2026E-PD. Canada Revenue Agency. Eligibility criteria, the five step process, validity, processing times and the statement on appeals.

CRA program pages

• Scientific Research and Experimental Development (SR&ED) tax incentives. Canada Revenue Agency. Program page: purpose of the incentives.
• What are SR&ED tax incentives. Canada Revenue Agency. Sections on the deduction, the investment tax credit and provincial and territorial tax credits.
• After you claim. Canada Revenue Agency. Processing, selection for review and objections.
• SR&ED Program Service Standards. Canada Revenue Agency. Standards for claims accepted as filed and refundable claims selected for review.
• Apply for pre-claim approval. Canada Revenue Agency. Eligibility criteria and the steps to apply.
• Request a case number, pre-claim approval. Canada Revenue Agency. Web form and contact times.
• Complete your application, pre-claim approval. Canada Revenue Agency. Instructions for Parts 1 to 3 of Form T1322.
• Submit your application, pre-claim approval. Canada Revenue Agency. Submission through My Business Account and the business's responsibility for the information.
• Resolving disputes, corporations. Canada Revenue Agency. Objection deadline, filing methods, large corporations and the appeals officer's review.
• About Represent a Client. Canada Revenue Agency. What the portal is and who can use it.
• Levels and scope of authorization that you can give representatives of your business. Canada Revenue Agency. Authorization levels for business representatives.

CRA notices, news and consultations

• SR&ED T661 Claim Form, 2013 Revision, Claim preparer information (October 31, 2013). Canada Revenue Agency. Introduction of Part 9 and the application date of the penalty.
• SR&ED T661 Claim Form, Revised optional filing measure for Part 9 (May 30, 2014). Canada Revenue Agency. The administrative measure permitting Part 9 of Form T661 to be filed separately.
• SR&ED news and updates. Canada Revenue Agency. Item "Dentistry professionals: look out for third parties promising access to SR&ED tax incentives".
• Advisory for businesses claiming SR&ED investment tax credits (tax tip, October 12, 2022). Canada Revenue Agency. Claimant responsibility, third parties and the Voluntary Disclosures Program.
• Are you preparing to claim SR&ED tax incentives? Here's what you need to know (tax tip, May 30, 2023). Canada Revenue Agency. Part 9 information, review meetings and preparer guidance.
• Innovate with confidence: CRA's SR&ED Tax Incentive Program launches a new Pre-claim approval process (April 8, 2026). Canada Revenue Agency. Launch, eligibility, steps and timelines of pre-claim approval.
• Consultation on proposed enhancements to the Scientific Research and Experimental Development (SR&ED) Program. Canada Revenue Agency. Consultation report on proposed enhancements to the program, including the use of claim preparers.

Federal budgets

• Archived: Budget 2012, Scientific Research and Experimental Development (SR&ED) program. Canada Revenue Agency. Question 9: the study of contingency fee arrangements.
• Budget 2013, Scientific Research and Experimental Development (SR&ED) Tax Incentive Program. Canada Revenue Agency. Section on claim preparer information and the penalty.
• Budget 2025, Chapter 1. Department of Finance Canada. Section "Enhancing the Scientific Research and Experimental Development Tax Incentives", including the administrative improvements and pre-claim approval.

Professional bodies

• CPA Code of Professional Conduct. Chartered Professional Accountants of Ontario. Cover page; Definitions, "contingent fee"; Rule 215, Contingent fees (Rules 215.1 and 215.2 and Guidance).
• Avoiding complaints about fees (last revision 1 March 2018). Chartered Professional Accountants of British Columbia. CPABC Code of Conduct guidance on contingent fees.

Courts

No decision of the Tax Court of Canada or the Federal Court of Appeal is cited on the Canada pages at this stage.