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

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

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...

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