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Corporate Taxes Research and Development

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Miller Canfield

Some Research Credit Good News and Potentially Much Bad News

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Over an objection by the IRS, the Tax Court recently ruled in Kapur v. Commissioner that it could limit discovery and permit statistical sampling of voluminous data related to a claimed research credit. The court refused,...more

Eversheds Sutherland (US) LLP

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more

Morrison & Foerster LLP

European Digital Compliance: Key Digital Regulation & Compliance Developments - March 2023

To help organizations stay on top of the main developments in European digital compliance, Morrison Foerster’s European Digital Regulatory Compliance team reports on some of the main topical digital regulatory and compliance...more

Cooley LLP

Support Announced for R&D-Intensive SMEs in UK’s Spring Budget 2023, Other Changes to R&D Tax Relief Regime

Cooley LLP on

In recognition of the need to support the UK’s most innovative businesses, an additional tax relief for research and development-intensive small- and medium-sized enterprises (SMEs) was recently announced in the Spring Budget...more

Orrick, Herrington & Sutcliffe LLP

Spring Budget 2023: What Tech Companies Need to Know

On 15 March 2023, the Chancellor of the Exchequer delivered his Spring Budget, announcing a number of changes to tax measures and employee share schemes. Here are the key takeaways of particular relevance to our growth...more

Goodwin

France enacts the Finance Law for 2023 - Loi de Finances pour 2023

Goodwin on

La Loi de finances pour 2023 (LF 2023) a été publiée au Journal Officiel le 31 décembre 2022. Le présent bulletin décrit brièvement une sélection de mesures fiscales qu’elle contient. Veuillez consulter la publication...more

Barnea Jaffa Lande & Co.

District Court: Changing a Business Model after Purchasing Company Shares Does not Always Constitute a Tax Event

In May 2022, the Tel Aviv District Court issued an important ruling in the Medingo Ltd case on the tax aspects of business restructuring. This ruling joins a series of previous rulings, in the Gteko case and the Broadcom...more

Akin Gump Strauss Hauer & Feld LLP

House GOP Policy Priorities Going Forward: Tax Policies to Support Domestic Research, Development, and Manufacturing of Treatment...

On Monday, April 18, 2022, Reps. Vern Buchanan (R-FL), Mike Kelly (R-PA) and Brad Wenstrup (R-OH)—all Republican Members of the House Committee on Ways & Means—reintroduced several pieces of legislation meant to secure...more

Freeman Law

The Research and Development Credit – Section 41

Freeman Law on

Taxpayers are always interested in whether certain expenditures qualify as tax deductions. But many taxpayers often forget that expenditures may alternatively qualify for various tax credits. And all things being equal,...more

Wilson Sonsini Goodrich & Rosati

California Lifts Suspension of the Use of NOLs

In June 2020, California lawmakers passed legislation that limited use of net operating losses (NOLs) for California taxpayers with net business income of $1 million or more for the tax years 2020, 2021, and 2022. In...more

Orrick, Herrington & Sutcliffe LLP

Super deduzione per i costi di R&S e credito d’imposta – le novità del Decreto Fiscale

È prevista l'abrogazione del Patent Box e l'introduzione di una nuova opzione per la maggiore deducibilità del 90% dei costi di ricerca e sviluppo sui beni immateriali alternativa al credito d’imposta per attività di ricerca,...more

Orrick, Herrington & Sutcliffe LLP

Super Deduction for R&D Costs and Tax Credit - What's New in the Tax Decree

The tax decree October 21, 2021 no.146 provided the abolishing of the Patent Box regime and the introduction of a new optional regime providing an extra deduction (for Corporate income tax purposes as well as for the Regional...more

Eversheds Sutherland (US) LLP

The devil is in the details: Final infrastructure framework announced, fingers crossed for continued R&E deductibility

Democratic leadership announced today that an agreement has been reached to fund the pending infrastructure and budget reconciliation measures. There does not appear to be any agreement regarding which specific tax measures...more

Hogan Lovells

‘The American Jobs Plan’: Biden Administration unveils $2 trillion proposal for infrastructure

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On March 31, the Administration unveiled its long-awaited infrastructure proposal from the President’s Build Back Better Plan. The American Jobs Plan will impact a multitude of industries and the economy in seven key policy...more

Vinson & Elkins LLP

UK Budget 2021: Tax Perspectives

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On 3 March 2021, UK’s Chancellor Rishi Sunak announced the 2021 Budget, outlining the state of the economy and the government’s fiscal plans for the near to medium term. As expected, the chancellor’s speech focused on changes...more

Bowditch & Dewey

Tax Incentives for Manufacturing Corporations

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In these challenging times, businesses might seek to evaluate whether certain local tax incentives offered by the Commonwealth of Massachusetts are available to them. “Manufacturing Corporations,” for example, receive a...more

A&O Shearman

IRS Permits First Spin-off of R&D Intensive Business With No Pre Spin-off Income

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On February 28, 2020, the Internal Revenue Service (the “IRS”) released PLR 202009002, the first private letter ruling that will potentially permit a tax-free spin-off of a research and development (“R&D”) intensive business...more

K&L Gates LLP

German Act on Tax Incentives for Research and Development (FZulG) in Force

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The German Act on Tax Incentives for Research and Development became effective 1 January 2020. Under this act, companies and entrepreneurs subject to income or corporation tax in Germany, may apply for subsidies of up to 25%...more

Wilson Sonsini Goodrich & Rosati

IRS May Relax Collection of Income Prong of Section 355 Active Trade or Business Test for R&D Companies

On September 25, 2018, the Internal Revenue Service (the IRS) released a statement announcing a study of the "active trade or business" test for tax-free spin-offs under Section 355 (the ATB Test), as applied to...more

Mintz

Overview of Recent U.S. Tax Reform Part I – Certain Significant Changes Impacting C-Corporations

Mintz on

On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax...more

Orrick, Herrington & Sutcliffe LLP

Patent Box – Ultimi Aggiornamenti Dall’Agenzia Delle Entrate

As known the cd. "Patent Box" allows companies carrying out activities Research & Development to opt, as from the tax in 2015, for a taxation regime facilitated the income generated from the direct exploitation or indirect...more

McDermott Will & Emery

The Upcoming Implementation of the Italian Patent Box Regime

Several press articles in recent weeks have anticipated the upcoming enactment of the Ministerial Decree which will eventually implement the Italian Patent Box regime. The Ministry of Economics and Finance announced on 29...more

Dechert LLP

Publicly Traded Partnership Proposed Regulations

Dechert LLP on

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

McNees Wallace & Nurick LLC

Application and Sale of Restricted Tax Credits

The Pennsylvania Department of Revenue has issued detailed rules for the application and sale of various Pennsylvania tax credits. Corporation Tax Bulletin 2014-04 replaces Corporation Tax Bulletin 2011-03. The Bulletin...more

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