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...
In a case that had been working its way through the system on R&D credit, Federal Express (Fedex) has settle their lawsuit with Department of Justice and retained most of its R&D credits per a stipulated settlement that will avoid trial. Most notably, the DOJ...
In a decision dated September 7, 2012 relating to the Union Carbide (UCC) case, the Appellate Court agreed with the Tax Court on the topic of R&D tax credit supply costs. UCC argued it should be entitled to R&D costs and the credit for both supplies purchased...
On Thursday August 2, the Senate Finance Committee approved a tax extenders package including the R&D tax credit, wind energy credit and the AMT patch. This is a positive step towards addressing the R&D credit for 2012 and 2013 and the legislation is expected...
In a recent TC Memo case, the Tax Court determined that certain higher level individuals within a cosmetics company did not materially participate in the R&D process (or at least did not prove they participated) to substantiate their R&D claim. In Basim Shami...
