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Funded R&D – Rights – Tangel Case R&D Tax Credits

Funded R&D – Rights – Tangel Case R&D Tax Credits

by Bruce Warner | Feb 12, 2021 | Blog

In a recent Tax Court case, Tangel v. Commissioner, T.C. Memo. 2021-1 (Jan 2021), the Tax Court concluded that the taxpayer who claimed the R&D tax credit did not retain substantial rights and thus the R&D work was ‘funded’ and the R&D tax...
Settling R&D Tax Credit Base Period Issues with IRS – Audio Technica Case 2020

Settling R&D Tax Credit Base Period Issues with IRS – Audio Technica Case 2020

by Bruce Warner | Sep 22, 2020 | Blog

In a recent Appellate decision in Audio Technica v. U.S.[1], the Appellate court overturned a district court decision on defining the fixed base percentage for the taxpayer Audio Technica and its R&D tax credit claim. Audio Technica claimed the R&D tax credit...
Settling R&D Tax Credit Base Period Issues with IRS – Audio Technica Case 2020

Populous Contracts are Not Funded R&D for R&D Tax Credit

by Bruce Warner | Jan 26, 2020 | Blog

In a December 2019 motion, the taxpayer Populous Holdings, an architectural design firm, won the motion allowing them to claim the R&D tax credit on its contracts with clients. Populous claimed the R&D tax credit for architectural work it does for clients and...
Settling R&D Tax Credit Base Period Issues with IRS – Audio Technica Case 2020

R&D Tax Credit / R&D Expenses – Changes in New Tax Bill December 2017

by Bruce Warner | Dec 27, 2017 | Blog

The R&D tax credit was preserved in the final tax bill, known as the Tax Cuts and Jobs Act, thus retaining this important tax credit for businesses to continue to incentivize retaining R&D and tech jobs in the U.S. The Conference Committee also eliminated the...
Settling R&D Tax Credit Base Period Issues with IRS – Audio Technica Case 2020

AMT Alternative Minimum Tax could impair R&D tax credit in Senate Bill

by Bruce Warner | Dec 6, 2017 | Blog

Although the R&D tax credit has been retained in the 2017 tax bills (both versions), in Conference Committee, the Congress will have to work out what to do with AMT. The House bill repealed the corporate AMT (Alternative Minimum Tax that corporations must  pay)...
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Recent Posts

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  • ERC Compromise Reached – OBBB One Big Beautiful Bill Act July 2025
  • IRS Clarifies Income Tax Handling of ERC Refunds – Employee Retention Credit

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