Section 45L Energy Credits – What Qualifies?
What Construction Qualifies for the Section 45L Energy Tax Credit? The energy tax credit for residential construction is a very valuable tax credit for developers and builders of single and multi-family homes and apartments in the U.S. This credit incentivizes using...
R&D Tax Credit Bill – Proposes Extending the R&D Credit for 2014 and 2015
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 - the...
Online Software Regs – Section 199 Domestic Production Deduction – Taxpayer must show substantially identical software
Under existing IRS regulations on Section 199, the Domestic Production Deduction, software qualifies for 199 treatment, but online software may or may not depending upon whether certain exceptions are met. As with other qualifying domestic production property under...
5th Circuit Largely Affirms Tax Court Decision in Shami v. Commissioner – R&D Credit Case
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...
New R&D Tax Credit Regs – Intercompany Gross Receipts / Foreign Gross Receipts
The Internal Revenue Service (IRS) and Department of Treasury (Treasury) have proposed new regulations regarding the calculations of gross receipts in relation to intra-group transactions between members of a controlled group claiming the research and development...
New Section 174 R&D Regulations – R&D Expenditures
The IRS recently published new proposed regulations for research & development (R&D) costs under Section 174 that amend some of the rules around what costs qualify under Section 174 for an R&D deduction. In general, these amendments attempt to quell...
New Section 199 Domestic Production Activities Deduction Case – ADVO Tax Court Case Printer Publisher
In a new Section 199 Domestic Production Activities Deduction case, the Tax Court has ruled that a third party contract printer is entitled to the Section 199 deduction and not the publisher. ADVO, Inc. v. Commissioner, 141 T.C. 9 (2013). ADVO is a direct mail...
North Carolina R&D Credit Overview – Extended Through 2015
The Technology Development Tax Credit in North Carolina has been renamed the Research & Development (R&D) tax credit as of mid-2013 but the same rules apply and this credit is now extended through 2015. Taxpayers may claim eligible R&D expenses for the...
Wisconsin R&D Credit – Overview and Update
Wisconsin R&D Tax Credits The Wisconsin Research Tax Credits (R&D tax credits) provide an incentive to increase qualified research activities and facilities within the state of Wisconsin. The R&D credits are nonrefundable and can be used to offset...
Treasury Issues Final Regulations on Repairs and Maintenance
On September 13, 2013, the IRS and Treasury Department released the final regulations (T.D. 9636) on repairs and maintenance providing guidance for the treatment of expenditures incurred in acquiring, producing, or improving tangible assets (commonly known as the...
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