News & Analysis as of

Research and Experiment Tax Credit

Miller Canfield

How Big is the Permanent Tax Benefit in the Pending Tax Bill for Research Credit?

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Congress perhaps made an unintended drafting error in the Tax Cuts and Jobs Act (TCJA) when it required a taxpayer to decrease its deduction for research and experimental expenditures....more

Miller Canfield

In a Pending Research Tax Credit Case the IRS Fails to Follow Regulatory Language

Miller Canfield on

The stream of cases challenging disallowance of research tax credits continues in the Tax Court with Phoenix Design Group, Inc. v. Commissioner. The taxpayer in Phoenix Design designs mechanical, electrical, and plumbing...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

McDermott Will & Emery

Taxpayer Loses Claim for Research Credit

McDermott Will & Emery on

In United States v. Grigsby, Docket No. 22-30764, the US Court of Appeals for the Fifth Circuit held that a refund claim based on claimed Internal Revenue Code (IRC) Section 41 credits was erroneous. Cajun Industries LLC, a...more

Eversheds Sutherland (US) LLP

Rise and shine: IRS and Treasury provide insight on Notice 2023-63 and treatment of R&E expenditures under Section 174

At this morning’s Federal Bar Association breakfast briefing hosted by Eversheds Sutherland, officials from the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) discussed the recent substantive...more

Wilson Sonsini Goodrich & Rosati

IRS Issues Interim Guidance on Capitalization and Amortization of Research and Experimental Expenditures Under Section 174 of the...

On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations...more

Eversheds Sutherland (US) LLP

The real deal? R&E amortization may be here to stay

The Tax Cuts and Jobs Act (TCJA) included a sunset provision for immediate expensing of research and experimentation (R&E) expenditures, generally providing that such expenses would be subject to five-year (domestic R&E) or...more

Eversheds Sutherland (US) LLP

An apparent 180 degree turn by the Service with research credit claims

On January 3, 2022, the IRS Office of Chief Counsel released an interim guidance memorandum (the Interim Guidance), along with a set of FAQs, to provide IRS Examining Agents with procedural guidance for applying Field...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

Miller Canfield

The Research Tax Credit and the Substantially-All Test

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A recent United States Tax Court decision raises a high bar for taxpayers claiming federal income tax credits for research expenses. The case turned on whether the taxpayer proved that "substantially all" of its research...more

Bradley Arant Boult Cummings LLP

Proposed Updates to Alabama Business Tax Laws: Summary of the Financial Institution Excise Tax Reform Act of 2019 and Alabama...

Two landmark bills were introduced in the Alabama Legislature on April 11, potentially affecting numerous businesses in the state. Committees of the House of Representatives are expected to consider the Financial Institution...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Manufacturing, Distribution and Retail Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

K&L Gates LLP

Washington State Tax Update

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The Washington Legislature released the state budget for the 2015-2017 biennium, which enhanced the state’s nexus standard, eliminated certain tax exemptions, extended some tax preferences, and made other tax changes:...more

McDermott Will & Emery

Key Energy-Related Tax Provisions in the 2016 Budget Proposal

McDermott Will & Emery on

In This Issue: - Modify and Permanently Extend the Production Tax Credit - Enhance and Make Permanent the Research and Experimentation Tax Credit - Provide Carbon Dioxide Investment and Sequestration Tax Credits ...more

Bennett Jones LLP

Feedlot Health Management Services Ltd v The Queen, 2015 TCC 32 - The Tax Court Considers Fundamental SR&ED Principles

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Bennett Jones LLP represented Feedlot Health Management Services Ltd. (FHMS) in the recent Tax Court of Canada proceeding, Feedlot Health Management Services Ltd v The Queen (2015 TCC 32). The case concerned certain...more

King & Spalding

House Approves Bill to Make R&D Tax Credit Permanent

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On May 9, the U.S. House of Representatives passed the American Research Competitiveness Act of 2014, which would make permanent the expired research and development (R&D) tax credit. The bill, H.R. 4438, passed...more

Nexsen Pruet, PLLC

Comparison of Economic Development Incentives for South Carolina and North Carolina

Nexsen Pruet, PLLC on

In This Presentation: - Business Consideration – Electricity Rates - South Carolina vs. North Carolina - Corporate License Fees/ Franchise Taxes - Income Tax Rates (C Corps) - Income Tax...more

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