I have had 2 “pre-assessment” phone calls from the Canada Revenue Agency asking how we calculated the Capital Cost Allowance on the fixed asset additions on Schedule 8. From what I can tell the CRA software may not have been updated to account for the recently passed (March 26, 2026) bill C-15?
The TaxCycle software seems to be calculating the RIIP properly to include the enhanced claim on fixed asset additions, but the CRA agents are telling me that for additions such as class 8 and class 10 you can only use the general CCA rate for both UCC opening balances and current year additions.
For instance; class 8 with UCC opening of 100,000 and year 2025 additions of 20,000.
TaxCycle (and myself) are calculating CCA to be 26,000 (20% of 100k + 30% of 20k)
CRA is telling me maximum CCA claim is 24,000 (20% of 100k + 20% of 20k)
Wondering if anyone else had any pushback on T2 returns? From what I can remember all of the T1 returns went through without any resistance using the new RIIP rules.
I looked through the “Royal Assented” version of bill C-15.
Page 213 of the pdf document (in the Income Tax Regulations area) new subsection 1104(4.01) defines “Reaccelerated Investment Incentive Property” (RIIP)
Pages 205 to 207 of the pdf document (in the same Income Tax Regulations area) subsection 1100(2) provides the updated mechanics of calculating capital cost allowance on the fixed asset additions, including the enhanced first year deductions for RIIP additions.
The CRA are definitely wrong in their current position of completely ignoring the new RIIP regulations.
@snoplowguy For T2, CRA was administering RIIP before Bill C-15 received Royal Assent on March 26, 2026. Currently, TaxCycle T2 Schedule 8 is still the old form (before RIIP was incorporated) and we simply updated the CCA calculation to incorporate RIIP (CRA gave us the permission to do so for T2) while keep the old form as is.
The updated Schedule 8 (which incorporates RIIP) is not yet available publicly but in the next T2 release (tentatively first week of June or earlier) will include the updated Schedule 8. I know that there was a T2 CRA system update on the weekend leading up to May 11th which incorporated this updated Schedule 8 with new line numbers and I am wondering if this is causing some confusion amongst the CRA field agents.
If you would like, I can reach out to the CRA. To do that, I will need your help. Are you able to send me the T2 file with contact detail of the CRA field agent? If there was a written preassessment review letter, I would like to ask for a copy as well.
I spoke with the field agent directly this morning (no letter received) and left a follow up voicemail later this afternoon pointing him in the right direction once I had found the legislation. If you also want to try to call him, that would be appreciated.