The recent MBJ v. Commissioner ruling highlights the important role of contract language in determining eligibility for Research and Development (R&D) Credits. MBJ, a structural engineering firm, had $190,000 in credits disallowed due to inadequate contract language. Although MBJ's contracts allowed for phase inspections and termination for substantial failure to perform, they lacked explicit provisions making payments contingent on the success of R&D efforts or refunding payments if the client found the work deficient. ...

A recent Tax Court ruling in S Moore v. Commissioner serves as a reminder of the important role documentation plays in supporting claims for research credits. In this case, the Tax Court disallowed a tax credit for research expenses claimed by a married couple due to inadequate documentation....

On Thursday, March 21, the Senate Finance Committee held a hearing on the Biden 2025 Budget Proposal, questioning Treasury Secretary Janet Yellen on various aspects of the proposed budget, with many members noting concern about the proposed increase of the corporate tax rate and aspects of the budget that would have a negative impact on various American manufacturing industries. After weeks of silence from the Senate, many members of the committee stated their desire to see the tax bill (H.R. 7024) passed while urging Yellen and the administration for more aggressive incentivization of R&D in the US, which falls short in incentivizing R&D when compared to countries, specifically China....