The U.S. Tax Court recently issued its opinion in Deere & Co. et. al. v. Commissioner, 133 T.C. 11 (2009), holding that the taxpayer must include its foreign branch income in its research tax credit calculation. Deere & Co. received income from its branches in Germany, Italy and Switzerland. Deere & Co. filed a consolidated [...]
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For each of the taxable years ended Oct. 31, 1997 through 2001, the total income that P, a consolidated group of corporations, reported in its consolidated return included amounts from the operations during each of those taxable years that the parent of P (Parent) conducted through its foreign branches (Parent’s foreign branch operations). In calculating [...]
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Tags: research tax credit
Posted in R&D Tax Credit Court Cases • No Comments »
Why read about the R&D tax credit on the web, when you can buy the book?