by admin | Sep 26, 2012 | Blog
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...
by admin | Sep 9, 2012 | Blog
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...
by admin | Aug 24, 2012 | Blog
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...
by admin | Aug 13, 2012 | Blog
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...
by admin | Jun 30, 2012 | Blog
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...
by admin | Apr 24, 2012 | Blog
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...
