by Bruce Warner | Oct 4, 2016 | Blog
The IRS has issued final regulations largely adopting provisions in the January 2015 proposed regs on internal use software. These final R&D regulations on internal use software are effective prospectively for tax years ending after October 4, 2016. The new final...
by Bruce Warner | 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 Bruce Warner | 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 Bruce Warner | 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...
