News: IRS

Settling R&D Tax Credit Base Period Issues with IRS – Audio Technica Case 2020

In a recent Appellate decision in Audio Technica v. U.S.[1], the Appellate court overturned a district court decision on defining the fixed base percentage for the taxpayer Audio Technica and its R&D tax credit claim. Audio Technica claimed the R&D …

Tagged , , , , , ,

Use the R&D Credit to Offset your Payroll Tax – New Webinar available online !

Clients who already filed their 2016 tax returns can now take advantage of a ONE TIME opportunity from IRS – file an amended 2016 tax return before 12/31/17 and you can still claim the R&D credit towards your payroll tax …

Tagged , , , , , ,

R&D Credit – New IRS Safe Harbor for R&D Costs

On September 11, 2017, the commissioner of the Large Business & International (LB&I) Division of the IRS issued new guidance for taxpayers using ASC 730 to expense research and development costs on their financial statements. This directive (LB&I-04-0917-005) provides a …

Tagged , , , , , , , ,

R&D Tax Credit – Payroll Tax Offset – IRS Notice 2017-23

In December 2015, Congress passed the PATH Act of 2015, which enabled small, start-up businesses to use the R&D Tax Credit to offset the employer portion of payroll taxes, up to $250,000. To qualify as a small, start-up, the Taxpayer …

Tagged , , , , , , ,

R&D Tax Credit Payroll Tax Offset – Starting in 2017!

The new Path Act which was passed in Congress December 2015 kicks in effective for tax year 2016.  One significant new provision is that start up companies can use up to $250,000 in R&D credits against their 2017 quarterly payoll …

Tagged , , , , ,

Final Regs Internal Use Software – R&D – What is the Dual Purpose Rule?

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 …

Tagged , , , , , , , ,

IRS Issues Final Regulations on Internal Use Software – R&D Tax Credits

The IRS has issued final regulations largely adopting provisions in the January 2015 proposed regs on internal use software. These final R&D regulations on internal use software are effective prospectively for tax years ending after October 4, 2016. The new …

Tagged , , , , , , , , , , , ,

R&D Credits to Offset Payroll Taxes in 2017 if you qualify

Under the December 2015 Path Act, Congress will provide additional R&D tax credit incentives for small business, as defined as a company with less than $5 million in receipts and no history of receipts longer than 5 years – stated …

Tagged , , , , , , , , ,

Online Software – Latest IRS Thinking – Section 199 Domestic Production Activities Deduction

Currently the IRS is working on updating its guidance regarding online software which we expect some additional guidance early in 2016. Online software under Section 199 is generally not qualified for the Domestic Production Activities Deduction (Section 199 deduction) unless …

Tagged , , , , , , ,

Section 199 Domestic Production Deduction – New IRS Proposed Regulations – Contract Manufacturing

One area of dispute for many years under the Section 199 Domestic Production Activities Deduction was in situations where the taxpayer designs a product but a third party contract manufacturer actually produces the product under contract with the taxpayer. Prior to these new proposed regulations issued in August 2015, the benefits and burdens of ownership tests/criteria would be applied to determine which party can claim the Section 199 deduction.

Tagged , , , , , ,