What is the likelihood of changing a CRA reviewer’s mind after they have made a proposal about your claim? We have seen such a change occur, more than once, but such a result is a minority outcome.
This is unfortunate because we are increasingly finding that to CRA, SRED is whatever the RTA reviewing the claim says it is. Reviewers have a knack for sending lengthy documented refusals that are very short on technological information and reflect no relevant hands-on experience with the technology that is the context of the claim. Too often we see reviews done by people that display no evidence of technical proficiency in the activities for which the reviewed claim has been made. At one time such experiences were isolated but increasingly there appears to be an agency wide strategy within CRA to reduce claims and wear out claimants, albeit politely!
This is not to imply that your review will be done by incompetents. There are some very bright reviewers, and some really helpful ones, but the fact that appeals to SRED related assessments are now several times what they were a few years ago should say something about what is happening. This data on the number of SR&ED appeals is informative.
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