A new decision from the Court of Federal Claims in Dynetics v. United States asks the question what type of research is considered funded research for the R&D tax credit. In Dynetics, the taxpayer did not retain substantial rights to the research or was not...
R&D Tax Credit Update 2014 – New Tax Court case on R&D credits rules favorably for taxpayer on almost all aspects of the case involving development of hardware and software. The taxpayer developed telephone equipment and related software and claimed the...
In an overwhelming vote of 271 to 131, the House of Representatives passed a bill making the R&D tax credit permanent, rather than continuing to extend the R&D credit for 2 year periods which has been the norm for many years. Interestingly, the bill did not...
R&D Tax Credit 2014 Update: The Senate Finance Committee last week passed a tax extenders bill that included the R&D tax credit. The research credit would be extended under this bill for 2014 and 2015 and included a key aspect for flow through companies...
In the underlying TC Memo case Shami v. Commissioner, an R&D tax credit case, the Tax Court found that there was not sufficient evidence to show that two higher level managers were engaged in research activities for which the R&D credit was claimed based on...