The CRA Information Circular 86-4R3 was for many years the principal technical guidance document for the SR&ED program. The reference number indicates that it was originally published in 1986, was the fourth SR&ED document to be published that year, and had been revised three times. The third and final revision was published in 1994.
It held the distinction of being widely accepted by the courts and frequently referenced as an authority. The reason for this approval, as explained by Justice Bowman (in NWH, 1997), was the widespread consultations with stakeholders that went into its development: “It represents a broad consensus of persons in the public and private sector who are likely to be affected by or to have an interest in the interpretation of the SRED provisions of the Income Tax Act.”
In 1998, a fifth version of the IC, 86-4R4, was drafted by CRA and posted for comments. This new version was not well received by program users. It was criticised as more restrictive and less business-oriented than the older version, also as requiring a particular development model, and leaving too much to the discretion of individual reviewers. Due to public pressure 86-4R4 was cancelled later that year, and IC 86-4R3 continued to be the main technical reference document until its withdrawal in 2012. It is scheduled to be removed from the CRA website on June 28th, 2013.