The IRS is considering future guidance that could present opportunities for R&D phase businesses.
In a statement issued on September 25, 2018, the Internal Revenue Service (IRS) announced that it is studying the active trade or business requirement for tax-free spin-offs under Section 355 for entrepreneurial ventures whose activities consist of research and development (R&D) in lengthy phases, but have generated little to no income.
Please see full publication below for more information.