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Prior to 1994, a qualifying corporation for the purposes of the refund was generally a CCPC with taxable income not exceeding $200,000 in the preceding year. However, the 1993 budget modified this rule in the case of the SR&ED ITC so that, after 1993, refundability phases out as the prior-year taxable income of a CCPC (or associated corporate group) rises above $200,000 and is eliminated entirely at $400,000. This change was made to reduce the negative consequences of exceeding the $200,000 limit by even a small amount. The change eases the transition between the start-up phase and the period of expansion that small businesses typically experience and provides more certainty to their business planning. In order to focus ITC benefits on smaller CCPCs, the 1994 budget introduced a further change to phase out refundability after 1995 for CCPCs with taxable capital employed in Canada exceeding $10 million and to fully eliminate refundability for CCPCs with taxable capital employed in Canada exceeding $15 million.
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