Contract Research – Year End Tax Tips

Contract Research – Year End Tax Tips

As to contract research incurred close to year’s end (whether fiscal or calendar) we often get questions on which costs can be counted as Qualified Research Expenses (QRE) in the current tax year. Under Treas. Reg. Section 1.41-2(e), a contract research expense...
Contract Research – Year End Tax Tips

This Week in Congress – November 29, 2010

This should be a very busy and interesting week (couple of weeks) in Congress as both sides meet with President Obama tomorrow to hash through concerns including trying to resolve how both parties want to handle the George W. Bush expiring tax cuts of 2001 and 2003....
Contract Research – Year End Tax Tips

R&D Tax Credit – Extender Bill Update

The tax extenders have still not been acted upon by Congress as of October 2010 – extender bills are a recurring legislative issue because of their temporary nature. Each time an extender’s expiration approaches, Congress faces the choice to extend the tax...
Contract Research – Year End Tax Tips

New 90/10 Test for Prior Period Compensation

The IRS has issued a new Tier I Industry Director Directive on Domestic Production Deduction (DPD) #3 Field Directive Relating to Compensation and the Section 199 Deduction. The new IRS directive permits the allocation and apportionment of certain pre-199 (i.e.,...
Contract Research – Year End Tax Tips

New Research Credit Case: Trinity Industries

The latest in a series of recent research credit (R&D tax credit) cases, the Northern District of Texas issued an opinion on January 29, 2010 relating to the research credit for developing certain types of ships by Trinity Marine Group (TMG), a subsidiary of...
Contract Research – Year End Tax Tips

New IRS Rules on Disclosure of Uncertain Tax Positions

Disclosure of Uncertain Tax Positions – New IRS Guidance Forthcoming In a speech before the New York Bar Association on January 26th, 2010, IRS Commissioner Douglas Shulman announced that for certain corporations and other business taxpayers who have assets of...