New IRS Final Regs on the ASC Calc
The IRS last week published new final regulations relating to the Alternative Simplified Credit or ASC under Section 41(c)(5) which has been around since 2006. This calculation avoids having to go back to the 1980s base years and instead uses a rolling prior 3 year...
First Ever Tax Court Case on Section 199 Domestic Production Deduction
In the first Tax Court case opinion on Section 199 deduction activities, the Tax Court today sided with the taxpayer in Gibson & Associates, Inc. v. Commissioner, 136 T.C. No. 10 (February 24, 2011). The taxpayer undertook three types of construction projects in...
Section 199 Deduction – 2010 Rate is Now 9%
The Section 199 Deduction is a valuable tax deduction for domestic production and manufacturing activities to incentivize retaining manufacturing jobs in the U.S. The definition of 'production' is also broad and also applies to software development and production of...
President Focuses on Innovation and R&D
Last night, President Obama focused squarely on innovation and R&D in the first third of his State of the Union address. Obama emphasized that the country faced a "Sputnik moment" and set goals around innovation, basic research funding, clean energy incentives,...
R&D Tax Credit Extended – December 17, 2010
The tax extenders package, which includes the R&D tax credit, was passed in the House last night and the President is expected to sign the bill later today. The package includes application of the R&D tax credit retroactive to January 1, 2010 and extends the...
New Tax Court Motion on Gross Receipts : Hewlett-Packard
In a Motion file with the Tax Court on Monday December 6, 2010, the IRS agreed that Hewlett-Packard Co. does not need to include amounts accrued from its controlled foreign subsidiaries (CFSs) in computing its gross receipts for purposes of the Research Credit, which...
Contract Research – Year End Tax Tips
As to contract research incurred close to year's end (whether fiscal or calendar) we often get questions on which costs can be counted as Qualified Research Expenses (QRE) in the current tax year. Under Treas. Reg. Section 1.41-2(e), a contract research expense is 65...
This Week in Congress – November 29, 2010
This should be a very busy and interesting week (couple of weeks) in Congress as both sides meet with President Obama tomorrow to hash through concerns including trying to resolve how both parties want to handle the George W. Bush expiring tax cuts of 2001 and 2003....
R&D Tax Credit – Extender Bill Update
The R&D credit expired as of 12/31/2009 and has yet to be extended by Congress although it has received attention as of late, including discussions by the President calling for a permanent R&D credit.
New 90/10 Test for Prior Period Compensation
The IRS has issued a new Tier I Industry Director Directive on Domestic Production Deduction (DPD) #3 Field Directive Relating to Compensation and the Section 199 Deduction.
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