In Technical Advice Memorandum 201034017 (Aug. 27, 2010), the parent of a consolidated group purchased the stock of a target company that was itself a parent of a consolidated group. The stock sale did not qualify as a tax-free transaction under I.R.C. §§ 355 or 368. The target company’s consolidated group was terminated because of [...]
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Posted in Federal R&D Tax Credit News, R&D Tax Credit Rulings
The Bayer Corp. & Subs v. United States, Civil Action Nos. 08-693, 09-351 (W.D. PA 2010), court case shows how important it is to place information and security controls on information gathered when preparing a research tax credit.
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Tags: R&D tax credit, research and experimentation, research tax credit
Posted in Federal R&D Tax Credit News
// The United States v. Goertz, No. A-09-CA-179 LY (W.D. Tex. 2010) case highlights why defending R&D tax credits on audit is often frustrating for taxpayers and the government alike. The short answer, is that it comes down to documentation. The court case does not say why the taxpayer’s research tax credit claim was denied. [...]
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Tags: R&D tax credit, research and experimentation, research tax credit
Posted in Federal R&D Tax Credit News
ANDREW W. AUSTIN, District Judge. Before the Court are Plaintiff’s Expedited Motion for Leave to Exceed Depositions under Rule 30 (Clerk’s Docket No. 40); Defendants’ Motion to Compel Responses to Interrogatories (Clerk’s Docket No. 43); and Defendants’ Motion to Enter Protective Order (Clerk’s Docket No. 45). The District Court referred the above-motions to the undersigned [...]
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Tags: R&D tax credit, research and experimentation, research tax credit
Posted in R&D Tax Credit Court Cases