California Changes Decision on Service Companies and R&D Credits
In an interesting turn of events, our blog entry below on limiting the California R&D credit to companies that can show sales of tangible personal property (Legal Division Guidance 2011-06-01), the Franchise Tax Board has withdrawn this guidance. This means...
Guidance from Treasury and the President on Effectiveness of the R&D Credit
The Office of Tax Policy, Department of Treasury issued a very informative summary this year outlining the President’s approach to the research credit. In the attached document, the letter reviews proposals from President Obama’s administration on making the federal R&D credit more effective in retaining and creating jobs in the U.S.
California Provides Guidance on R&D Credit Gross Receipts
The California R&D tax credit differs from the Federal R&D credit in a notable way - for California purposes, sales of property are included in the gross receipts calculation, but services income, rent, lease income, interest and other non-property income...
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...
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