New Tax Court Case Confirms Burden is on Taxpayer to Substantiate Base Period for the IRC §41 Research Credit
A recent court case denied a taxpayer the Research Credit under IRC §41 since it could not substantiate proper use of the “start-up” base period to calculate its credit rather than use of the 1984-1988 base period. IRC §41 permits a taxpayer to use a base period of either 1984-1988...
What Does the Tax Cuts and Jobs Act of 2017 (“TCJA”) Mean for the R&D Tax Credit?
While many deductions and credits were repealed by TCJA, the final law preserved the Research and Development (“R&D”) tax credit, which was previously made permanent in the Protecting Americans against Tax Hikes (“PATH”) Act of 2015...
Republicans Release Tax Overhaul Outline
On September 27, 2017, Donald Trump and the Republican Party released an outline of their tax overhaul plan. While this framework is not law, it shows their vision for both individuals and businesses. Below is a summary of major changes...
The IRS released final regulations concerning the application of the R&D tax credit to “internal use software”
The IRS released final regulations concerning the application of the R&D tax credit to “internal use software” (i.e., software which is developed by or for the benefit of the taxpayer). Examples of internal-use software include software for use in human resources, support services and financial management. Software that is not...