by Bruce Warner | Dec 21, 2015 | Blog
On Friday December 18, 2015, the President signed into law what normally would be a ‘tax extenders’ bill but with respect to the R&D tax credit, the credit was made permanent and no longer will expire every year or two. Companies can now rely on the R&D tax...
by Bruce Warner | Dec 13, 2015 | Blog
In a recent Field Attorney Advice (FAA) memo 20154501F, the IRS took a different approach to auditing this R&D tax credit claim. In this case, a CEO in charge of a group of companies was claimed at 60% qualified in supporting the companies’ R&D activities and...
by Bruce Warner | Dec 9, 2015 | Blog
The general rule for R&D tax credit documentation is found under IRC 6001 – a taxpayer must retain documentation in usable form to substantiate (in this case the R&D tax credit), and IRS typically wants to see evidence of the R&D in the form of...
by Bruce Warner | 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 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...
