ASC Alternative Simplified Credit on Amended Return – R&D Tax Credits
Under new IRS Regulations issued this week (T.D. 9666), taxpayers can now claim the R&D tax credit using the alternative simplified credit method, or ASC on amended tax returns. Previously this election to claim the ASC for R&D credits had to be made on...
R&D Tax Credit – Progress on Permanent Research Credit – House Bill Passes
In an overwhelming vote of 271 to 131, the House of Representatives passed a bill making the R&D tax credit permanent, rather than continuing to extend the R&D credit for 2 year periods which has been the norm for many years. Interestingly, the bill did not...
Energy Efficient Home Tax Credit – Sec. 45L – FAQ No. 1 – Who can claim the credit – Homeowner or Builder?
The energy tax credit under Internal Revenue Code Section 45L for energy efficient construction is a valuable tax credit for incentivizing using energy efficient lighting, HVAC, insulation, windows and other aspects that results in the home or apartment using less...
Key Factors in Meeting the Energy Efficient Home Requirements – 45L Energy Tax Credit
To obtain the valuable $2000 per unit energy tax credit under Code Section 45L, developers often ask us what are the key factors used in the modeling software to determine whether their buildings qualify under Section 45L for the credit. The software calculates...
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...
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