IRS Issues Guidance on Section 174 – No Form 3115 for 174 R&E Costs: Rev. Proc. 2023-11 has been issued by the IRS, offering simplified procedures for the first taxable year starting after December 31, 2021 (so calendar year taxpayers’ year 2022). Instead of...
Final R&D tax credit regulations published by the Treasury on October 4, 2016 regarding internal use software introduce a new term, dual function software, as well as a safe harbor provision. Dual function software is “software developed for both internal use and...
The general rule for R&D tax credit documentation is found under IRC 6001 – a taxpayer must retain documentation in usable form to substantiate (in this case the R&D tax credit), and IRS typically wants to see evidence of the R&D in the form of...
These important new proposed regulations issued last week on the R&D tax credit affect what is known as internal use software or IUS which has been debated since Congress distinguished internal use software from other software back in 1986. Over many years, there...
The IRS has recently ruled in GLAM – General Legal Advice Memorandum 2014-008 that a banking taxpayer who provides an app to access a customer’s bank accounts did not meet the exceptions to the Section 199 Domestic Production Activities Deduction online...
