by admin | Apr 7, 2014 | Blog
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...
by admin | Feb 24, 2014 | Blog
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...
by admin | Feb 10, 2014 | Blog
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...
by admin | Dec 17, 2013 | Blog
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...
by admin | Nov 4, 2013 | Blog
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...
by admin | Oct 30, 2013 | Blog
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...