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Internal Revenue Service › Internal Revenue Code (IRC) › Research and Experiment Tax Credit

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Miller Canfield

The Tax Court Recently Decides Two Research Credit Cases: One Favorable on Funding (Smith) and One Unfavorable on the Four-Part...

Miller Canfield on

Taxpayers had mixed success in two recent research credit cases in the United States Tax Court. In Smith v. Commissioner, the taxpayer was an architectural firm....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

Miller Canfield

The Research Tax Credit and the Substantially-All Test

Miller Canfield on

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

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