Online Software – Latest IRS Thinking – Section 199 Domestic Production Activities Deduction
Currently the IRS is working on updating its guidance regarding online software which we expect some additional guidance early in 2016. Online software under Section 199 is generally not qualified for the Domestic Production Activities Deduction (Section 199...
Section 199 Domestic Production Deduction – New IRS Proposed Regulations – Contract Manufacturing
One area of dispute for many years under the Section 199 Domestic Production Activities Deduction was in situations where the taxpayer designs a product but a third party contract manufacturer actually produces the product under contract with the taxpayer. Prior to these new proposed regulations issued in August 2015, the benefits and burdens of ownership tests/criteria would be applied to determine which party can claim the Section 199 deduction.
Funded Research R&D Tax Credit – Dynetics, Inc. v. United States New Case on Risk and Rights
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.
New Long Awaited R&D Credit Regs on Internal Use Software
These important new proposed regulations issued last week on the R&D tax credit affect what is known as internal use software or IUS which has been debated since Congress distinguished internal use software from other software back in 1986. Over many years, there...
Section 199 – Online Software Ruling – Domestic Manufacturing Deduction
The IRS has recently ruled in GLAM - General Legal Advice Memorandum 2014-008 that a banking taxpayer who provides an app to access a customer's bank accounts did not meet the exceptions to the Section 199 Domestic Production Activities Deduction online software regs...
Senate Passes Energy Tax Credit 45L for 2014
The Senate passed the energy tax credit (energy efficient home tax credit) for 2014 yesterday, December 16, 2014, adopting the House bill from a few weeks ago, part of the tax extenders bill extending the 45L energy credit for one year (2014). The 45L energy tax...
Senate Passed R&D Credit Extension – 2014
On December 16, 2014, the Senate approved the House bill extending the R&D tax credit for one year (retroactive for 2014). The President is expected to sign the R&D credit and other extenders into law today. Although the one year extension does not provide...
Update on R&D Tax Credit 2014 Extenders Bill
On Thursday, 12/11, Senate Leader Harry Reid indicated he wanted a vote on the tax extenders including the R&D tax credit and many other expired provisions during this session of Congress before the break. The order of priority was passing a bill to keep the...
R&D Tax Credit – Tax Extenders Bill 2014 – Vote on Thursday
Congress is expecting a vote on HR 5771, on Thursday which would extend the R&D tax credit and energy efficient tax credit under Section 45L for one year - meaning both tax credits would be retroactively enacted for 2014 (but would not cover 2015 under this bill)....
45L Energy Efficient Tax Credit – What Properties Qualify?
To claim the Section 45L energy efficient tax credit for residential properties, the developer/owner must review what types of properties qualify as 'residential or a dwelling unit'' and we are often asked this question. Under the 45L criteria, the energy credit rules...
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