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 credit...
Update – 45L Energy Efficient Home Tax Credit Extended on 12/27/2020
After a bit of drama over the COVID bill, the President did sign the legislation which included tax extenders on December 27, 2020 and this provides for a one year extension of 45L energy tax credits through 12/31/2021. The energy efficient home tax credit would have...
One Year Extension through 2021 for Energy Efficient Home Section 45L Tax Credit
The President is expected to sign the massive relief bill on Tuesday December 22, 2020 which (as part of the over 5,000 pages) includes tax extenders, notably the Section 45L Energy Efficient Home tax credit and the Section 179D energy efficient tax deduction for...
Sec 45L Energy Credit and the Election
In June 2020, a House bill was introduced referred to as the Moving Forward Act which would extend the Section 45L Energy Tax Credit for energy efficient homes through 2025. The bill would also increase the energy tax credit to $2,500 per unit/home and update the...
Settling R&D Tax Credit Base Period Issues with IRS – Audio Technica Case 2020
In a recent Appellate decision in Audio Technica v. U.S.[1], the Appellate court overturned a district court decision on defining the fixed base percentage for the taxpayer Audio Technica and its R&D tax credit claim. Audio Technica claimed the R&D tax credit...
45L Energy Credits in new House Bill – July 2020
In the first week of July 2020, The House of Representatives continued to advance the Moving Forward Act (H.R. 2) – the $1.5 trillion infrastructure proposal led by House Democrats. New programs created by H.R. 2 include a major extension and expansion of the Energy...
Populous Contracts are Not Funded R&D for R&D Tax Credit
In a December 2019 motion, the taxpayer Populous Holdings, an architectural design firm, won the motion allowing them to claim the R&D tax credit on its contracts with clients. Populous claimed the R&D tax credit for architectural work it does for clients and...
45L Energy Efficient Home Tax Credit Renewed for 2018-2020 years
An update on the tax extenders 2019 and the energy credits - the President signed into law an extension of the 45L energy efficient home tax credit last Friday. The energy tax credit is available retroactive for homes or apartments leased/sold starting on January 1,...
45L Energy Efficient Home Tax Credit Passes House – Tax Extenders Bill Update
The House passed a bill today to address expired tax extenders including the Energy Efficient Home Tax Credit under Section 45L and including the 179D energy deduction for commercial construction. The bill is expected to pass the Senate and move on to the President...
Status of 45L Energy Efficient Home Tax Credit – November 2019
Many of our clients have been asking about an update on whether Congress will re-new the Section 45L energy efficient home tax credit which allows developers to claim a $2,000 per door tax credit for homes or apartment complexes meeting certain energy efficient...
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