FedEx Prevails in R&D Credit Case – Discovery Test does not Apply
In a case that had been working its way through the system on R&D credit, Federal Express (Fedex) has settle their lawsuit with Department of Justice and retained most of its R&D credits per a stipulated settlement that will avoid trial. Most notably, the DOJ...
Taxpayer Gets a Gift (Basket) – New Section 199 Case – Domestic Production Deduction
In perhaps a surprising outcome, a district court has ruled that assembling gift baskets qualifies as manufacturing for purposes of the Section 199 Domestic Production Activities Deduction (or Section 199 deduction). The company produces gift baskets from purchasing...
Funded R&D – Taxpayer Wins Geosyntec Motion on R&D Credits
In another recent R&D tax credit case, upon motion, the U.S. District Court for the Southern District of Florida reviewed the important aspects of 'funded R&D' and determining which party obtains the R&D tax credit. The R&D credit is determined in part...
Warner Robinson’s Newest Team Member – Marcus Weaver, SCSP
Warner Robinson is very pleased to announce the arrival of Marcus Weaver, SCSP to the WR team as our new Managing Director. Marcus oversees our Cost Segregation operations nationally and is also subject matter expert on our 263(a) Repairs vs. Capitalization...
Marcus Weaver, SCSP of Warner Robinson elected to the ASCSP Board of Directors (2013 – 2015)
Marcus Weaver of Warner Robinson, our cost segregation specialist, is a Senior member of the American Society of Cost Segregation Professionals (ASCSP) and has held the office of Treasurer for the last two years. As an Executive Committee member and liaison to the...
Florida Research & Development (R&D) Tax Credit – 2012 – $9 million credit application process closed
For 2012 the ability to claim a portion of the $9 million available to be allocated to qualifying companies has expired. Florida requires companies apply for the $9 million pool of R&D credits on March 20 at 8:00 AM ET of each year that the credit is available. ...
Georgia Research & Development (R&D) credit eligible against payroll withholding taxes – 30 day and 120 day rules
Most calendar year companies that have extended their Georgia income tax return already know whether or not they are able to use the Georgia R&D credit to offset 50% of the entity’s taxable income. If the company knows that they cannot use the Georgia R&D...
President Calls for Permanent R&D Tax Credit and 17% ASC Rate
Under the President's New 2014 budget, the budget calls for making the R&D tax credit permanent so as to allow companies to plan R&D expenditures and associated credit with more certainty; moreover, the plan calls for increasing the alternative simplified...
Union Carbide R&D Tax Credit Case will not be heard by the Supreme Court
On March 18th, 2013, the Supreme Court declined to review a Second Circuit decision, affirming the Tax Court decision, finding that the taxpayer was entitled to a R&D tax credit for only additional supplies that were used to perform research. The Union Carbide...
IRS Issues Chief Counsel Advice on Section 199 Deduction
The IRS released a Chief Counsel Advice (CCA) memo on 3/29/13 on whether a publisher of books can claim a Section 199 domestic production deduction for its activities of producing books. However, the IRS segregated the activities into all activities up to the printing...
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