The Internal Revenue Service (IRS) and Department of Treasury (Treasury) have proposed new regulations regarding the calculations of gross receipts in relation to intra-group transactions between members of a controlled group claiming the research and development...
In a ruling dated September 24, 2012, the Tax Court held in the HP (Hewlett Packard) R&D tax credit case that gross receipts for purposes of determining the average annual prior 4 year receipts is not limited to line 1 minus returns and allowances (line 1c)....