News: R&D Tax Credit
California Changes Decision on Service Companies and R&D Credits
In an interesting turn of events, our blog entry below on limiting the California R&D credit to companies that can show sales of tangible personal property (Legal Division Guidance 2011-06-01), the Franchise Tax Board has withdrawn this guidance. This means …
Guidance from Treasury and the President on Effectiveness of the R&D Credit
The Office of Tax Policy, Department of Treasury issued a very informative summary this year outlining the President’s approach to the research credit. In the attached document, the letter reviews proposals from President Obama’s administration on making the federal R&D credit more effective in retaining and creating jobs in the U.S.
California Provides Guidance on R&D Credit Gross Receipts
The California R&D tax credit differs from the Federal R&D credit in a notable way – for California purposes, sales of property are included in the gross receipts calculation, but services income, rent, lease income, interest and other non-property income …
New IRS Final Regs on the ASC Calc
The IRS last week published new final regulations relating to the Alternative Simplified Credit or ASC under Section 41(c)(5) which has been around since 2006. This calculation avoids having to go back to the 1980s base years and instead uses …
R&D Tax Credit – Extender Bill Update
The R&D credit expired as of 12/31/2009 and has yet to be extended by Congress although it has received attention as of late, including discussions by the President calling for a permanent R&D credit.
New Research Credit Case: Trinity Industries
The latest in a series of recent research credit cases, the Northern District of Texas issued an opinion on relating to the research credit for developing certain types of ships by Trinity Marine Group.
New IRS Rules on Disclosure of Uncertain Tax Positions
IRS Commissioner Douglas Shulman announced that for certain corporations and other business taxpayers the IRS will start requiring that taxpayers disclose their uncertain tax positions.
New Research Credit Case: TG Missouri Decision Production Molds Qualified as Supplies
The U.S. Tax Court issued a decision November 12, 2009 that found TG Missouri (“TG”), an automotive parts manufacturer, properly included in research expenses, supply expenses related to production molds produced by a third party, in possession of TG, but sold to customers.
New Research Credit Case: Union Carbine Decision
The U.S. Tax Court issued a memorandum decision March 10 that found two of the five Union Carbide projects for which the company sought additional research credits under Section 41 of the Internal Revenue Code constituted qualified research.
