|
Why Self Funding?
Self funding is generally the first tranche of funding source
that is tapped by companies conducting research and development,
and one that often fits naturally with the high risk/high
reward ratio that is typically perceived in the early stages
by a key innovator within a company. This is often even a
necessary stage to reach a point of development whereby there
is something of substance to show for past efforts and to
provide a platform for outside funding requests.
What Is Self Funding?
For a start-up or early-stage company, self funding is backed
by the individual making the investment. It can take the form
of direct cash injections from founding shareholders, possibly
extending to the use of personal credit cards and leveraging
personal assets including homes. Another common source is
paying much less than market rates for key employees conducting
research and development. Each of these fund injections may
or may not be accompanied by formal agreements for future
stakes in the company (e.g. via stock options and their tax
deferral benefits) and/or the new product development when
eventually launched (e.g. via royalties). For a closely-held
private company, formal agreements may not be needed unless
there is asymmetry of sweat equity (or cash injection) to
future reward. The individuals affected ultimately tap into
their own private lines of credit and/or constrain their current
consumption for the future, an investment that they may have
varying degrees of control over as the development unfolds.
The emotional investment may be high and decisions on research
and development not always impartial.
Funding Research Alongside Commercial
Operations
For a company conducting research and development alongside
a business that is more or less commercially stable or growing,
self funding has the further option of diverting some or all
of the profit from that business to the new product development.
Although most shareholders in a public company expect a certain
degree of self funding, depending on the industry, defending
the funding of research from internal sources may be somewhat
contentious. For a small private company, decisions to re-invest
profit from current operations for the promise of future growth
are informed by the insider knowledge of the same individuals.
A small private company that operates a profitable business
alongside its R&D may need to be aware of the revenue
thresholds that may unexpectedly bump them from a 35% refundable
down to a 20% non-refundable status. TSGI can proactively
work with you to structure your organization to maximize your
future SR&ED tax credits.
The Negatives and Positives
of Self-Funding
The downside of self-funding is, most generally, that it can
be limited in magnitude especially for small start-ups or
even in public companies where the business cycle is volatile
and poorly synchronized with funding requirements. The natural
upside is that self-funding preserves the control and ownership
of the technology development held by the current owners and
shareholders without dilution from external sources. If the
research and development and the company is ultimately successful
and capital gains on the shares eventually realized, those
gains may be eligible for capital gains exemptions in private
companies and deferral of taxation on gains in both private
and public.
For refundable claimants (Canadian controlled private companies
or CCPCs) eligible for SR&ED tax credits specifically,
self-funding via below-market salaries can be very negative
because R&D tax credits can only recognize costs actually
incurred, not notional market salaries. Therefore when all
the factors are considered, including rules such as the “proxy
bump” (an SR&ED allowance for overhead costs that may
have the effect of increasing claimable costs related to salaries
of non-specified shareholders) and the numbers crunched, paying
below-market salaries for research and development may actually
leave the owners of a CCPC in a worse position than if full
market rates had been paid. TSGI can guide your company through
these and other complexities and apparent contradictions of
the SR&ED program.
|