News: proposed regs

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 …

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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.

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New Long Awaited R&D Credit Regs on Internal Use Software

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 …

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