by admin | Dec 8, 2015 | Blog
Currently the IRS is working on updating its guidance regarding online software which we expect some additional guidance early in 2016. Online software under Section 199 is generally not qualified for the Domestic Production Activities Deduction (Section 199...
by admin | Sep 25, 2015 | Blog
One area of dispute for many years under the Section 199 Domestic Production Activities Deduction was in situations where the taxpayer designs a product but a third party contract manufacturer actually produces the product under contract with the taxpayer. Prior to...
by admin | Sep 21, 2015 | Blog
A new decision from the Court of Federal Claims in Dynetics v. United States asks the question what type of research is considered funded research for the R&D tax credit. In Dynetics, the taxpayer did not retain substantial rights to the research or was not...
by admin | Jan 19, 2015 | Blog
These important new proposed regulations issued last week on the R&D tax credit affect what is known as internal use software or IUS which has been debated since Congress distinguished internal use software from other software back in 1986. Over many years, there...
by admin | Dec 28, 2014 | Blog
The IRS has recently ruled in GLAM – General Legal Advice Memorandum 2014-008 that a banking taxpayer who provides an app to access a customer’s bank accounts did not meet the exceptions to the Section 199 Domestic Production Activities Deduction online...
by admin | Dec 17, 2014 | Blog
The Senate passed the energy tax credit (energy efficient home tax credit) for 2014 yesterday, December 16, 2014, adopting the House bill from a few weeks ago, part of the tax extenders bill extending the 45L energy credit for one year (2014). The 45L energy tax...
