News: funded

Funded R&D – Rights – Tangel Case R&D Tax Credits

In a recent Tax Court case, Tangel v. Commissioner, T.C. Memo. 2021-1 (Jan 2021), the Tax Court concluded that the taxpayer who claimed the R&D tax credit did not retain substantial rights and thus the R&D work was ‘funded’ and …

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Populous Contracts are Not Funded R&D for R&D Tax Credit

In a December 2019 motion, the taxpayer Populous Holdings, an architectural design firm, won the motion allowing them to claim the R&D tax credit on its contracts with clients. Populous claimed the R&D tax credit for architectural work it does …

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What is considered “Funded” Research under the Research Credit Provisions (Section 41)

If an activity is “Funded” the taxpayer does not have financial risk and cannot claim the research credit for the project’s costs. However, if the payment is contingent upon successful completion of the work, then the taxpayer/contractor is at risk …

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