Canada: Your responsibility

An adviser can prepare Form T661, write the project descriptions and be named as the claim preparer in Part 9. None of that moves the claim out of the corporation's name. The claim is filed with the corporation's own T2 return, and if the Canada Revenue Agency later reduces it, your corporation pays the difference. The questions on who signs the claim and can we see the full claim before filing? are about making that responsibility real. The people who did the work read the project descriptions before the form goes in, and the corporation keeps a copy of what was filed.

There is one penalty the corporation shares directly with the preparer. If Part 9 of Form T661 has missing, incomplete or inaccurate claim preparer information, a $1,000 penalty can be assessed for each claim, and the claimant and the preparer are jointly and severally liable for it.1Source 1Canada Revenue Agency, T4088, Guide to Form T661, Part 9 (18 February 2026); Income Tax Act section 162(5.1) to (5.3) (current to 21 September 2026). Check Part 9 before you approve the form.

• The reporting deadline. The prescribed form must be filed on or before the day that is 12 months after the filing due date for the year. The corporation can request changes to the expenditures claimed up to that deadline; after it, no additional project or expenditure will be considered, and the CRA says it cannot by law allow more time.2Source 2Income Tax Act section 37(11) (current to 21 September 2026); Canada Revenue Agency, SR&ED Filing Requirements Policy (28 January 2025), sections 1.0, 5.3, 7.3 and 7.5. Test any offer to claim for an earlier year against this date (cold calls about unclaimed refunds).
• The CRA's reassessment period. The normal reassessment period ends three years after the original notice of assessment for a Canadian-controlled private corporation, and four years for other corporations. After that the CRA can reassess only where there was a misrepresentation attributable to neglect, carelessness or wilful default, or fraud, or where the corporation filed a waiver.3Source 3Income Tax Act section 152(3.1) and (4) (current to 21 September 2026). A claim can therefore be looked at well after the credit has been paid, which is why review support in the engagement letter matters (is review support included?).

If a review reduces the claim, your corporation repays the difference. Interest at the prescribed rate runs on tax unpaid after the balance-due day,4Source 4Income Tax Act section 161(1) (current to 21 September 2026). and a penalty for false statements or omissions can apply, the greater of $100 and 50% of the understated tax.5Source 5Canada Revenue Agency, Avoiding penalties (corporations) (5 May 2026). Whether the adviser's fee comes down too depends on the engagement letter, not on the CRA: see what happens to the fee if the claim is reduced?

Third parties who plan or prepare a false statement can face civil penalties of their own.6Source 6Canada Revenue Agency, IC01-1R2, Third-party civil penalties (17 February 2026), Income Tax Act section 163.2. Those penalties are the other person's; they do not pay the corporation's tax, interest or penalty, and the engagement letter's liability and indemnity clause is where any contribution from the adviser would be found.

A corporation asks the CRA to reassess its T2 return electronically through tax software, by sending bar codes, or by letter to its tax centre with the revised schedules; the CRA asks that the entire return is not resent.7Source 7Canada Revenue Agency, Requesting a reassessment of your T2 return (11 September 2026). For SR&ED, remember the reporting deadline: changes that add projects or expenditures are only possible before it.2Source 2Income Tax Act section 37(11) (current to 21 September 2026); Canada Revenue Agency, SR&ED Filing Requirements Policy (28 January 2025), sections 1.0, 5.3, 7.3 and 7.5. Take advice before you ask for a reassessment: the correcting a claim page sets out what to settle first, including what the engagement letter says about the fee on the corrected amount.

If the CRA reviews the claim within the reassessment period, it can ask for the evidence behind it. Keep the T2 return and Form T661 as filed, the project descriptions, the expenditure workings, the time and project records they rest on, and the engagement letter. Ask for anything the adviser holds that you do not (ownership of records and work).

• If your claim is reviewed and complaints about an adviser in Canada
• Claim reduced on review and if you are charged a penalty
• The true cost of a claim

Sources

1. Canada Revenue Agency, T4088, Guide to Form T661, Part 9 (18 February 2026); Income Tax Act section 162(5.1) to (5.3) (current to 21 September 2026).  Back
2. Income Tax Act section 37(11) (current to 21 September 2026); Canada Revenue Agency, SR&ED Filing Requirements Policy (28 January 2025), sections 1.0, 5.3, 7.3 and 7.5.   Back
3. Income Tax Act section 152(3.1) and (4) (current to 21 September 2026).  Back
4. Income Tax Act section 161(1) (current to 21 September 2026).  Back
5. Canada Revenue Agency, Avoiding penalties (corporations) (5 May 2026).  Back
6. Canada Revenue Agency, IC01-1R2, Third-party civil penalties (17 February 2026), Income Tax Act section 163.2.  Back
7. Canada Revenue Agency, Requesting a reassessment of your T2 return (11 September 2026).  Back