Warner Robinson’s Newest Team Member – Ken Schuckers
Warner Robinson is very pleased to announce the arrival of Kenneth Schuckers, CPA to the WR team as our new Managing Director. Ken brings over 22 years of corporate tax experience and has spent the last 13 years primarily focused on R&D tax credits and other...
R&D Tax Credit Extension Passed – 2012 and 2013
On Tuesday, Congress passed a two year R&D tax credit extension, retroactive for 2012 and through December 31, 2013 as part of the fiscal cliff deal. The R&D credit had little substantive changes, for example, no increase in the alternative simplified credit...
R&D Credit Extension – Awaiting Fiscal Cliff First
Although there has not been much news of action on the numerous expired tax provisions, including the R&D tax credit, Sen. Chuck Grassley (R-Iowa) stated this week that the Senate would wait to move on a $205 billion tax extenders package while President Obama and...
HP (Hewlett Packard) R&D Tax Credit – Gross Receipts includes Other Domestic Income Sources
In a ruling dated September 24, 2012, the Tax Court held in the HP (Hewlett Packard) R&D tax credit case that gross receipts for purposes of determining the average annual prior 4 year receipts is not limited to line 1 minus returns and allowances (line 1c)....
New Decision in Bayer R&D Credit Case
In a ruling on a Motion for Partial Summary Judgment filed September 20, 2012, the District Court hearing the Bayer R&D tax credit case denied the government’s Motion for Partial Summary Judgment. The government was seeking partial summary judgment arguing that...
R&D Case – Union Carbide (UCC) Appeal – Supplies Must be Direct R&D Expenses
In a decision dated September 7, 2012 relating to the Union Carbide (UCC) case, the Appellate Court agreed with the Tax Court on the topic of R&D tax credit supply costs. UCC argued it should be entitled to R&D costs and the credit for both supplies purchased...
End of Tier I Program for R&D Credit
The IRS released a statement on August 17 that it is ending its tiered issue program which includes the R&D tax credit, and will turn over review of previously listed issues to the newly organized issue practice groups (IPGs) and international practice networks...
Research Credit Extension Update August 2012
On Thursday August 2, the Senate Finance Committee approved a tax extenders package including the R&D tax credit, wind energy credit and the AMT patch. This is a positive step towards addressing the R&D credit for 2012 and 2013 and the legislation is expected...
Section 199 – Online Software – New CCA IRS Guidance
This week the IRS released a new Chief Counsel Advisory Opinion (CCA) regarding Online Software and Section 199. The key issue was applying the exception for software that is ‘substantially identical’ available from third parties via download or shrink-wrap. Thus, a...
Basim Shami Case – R&D Credit – Wages of Executives
In a recent TC Memo case, the Tax Court determined that certain higher level individuals within a cosmetics company did not materially participate in the R&D process (or at least did not prove they participated) to substantiate their R&D claim. In Basim Shami...
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