Court Says IRS Has Sufficient Info for R&D Tax Credit Sample Size

The court entered another order in the CRA Holdings U.S., Inc. v. United States, No. 15-CV-239W(F) (W.D.N.Y. 2017) case. The order addressed a dispute over the appropriate sample to be used to evaluate the taxpayer's ...
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Funded Research Tax Credit Article

The funded research rules can present a number of challenges. The rules can also limit drastically the amount of research tax credits available to taxpayers (1) who are paid to perform research (it limits their ...
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IRS Guidance for R&D Payroll Tax Credit

The IRS issued Notice 2017-23 to provide guidance to small businesses that want to use the research tax credit to offset their payroll taxes. The PATH Act of 2015 provided this election to taxpayers; however, ...
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Court Agrees to Judgment Sample for R&D Credit Claim

In CRA Holdings U.S., Inc. v. United States, No. 15-CV-239W(F) (W.D.N.Y. 2017), the court considered whether sampling was appropriate for a research tax credit claim based on 6,100 projects. The taxpayer asked the court to ...
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Government Lawsuit to Recoup Research Tax Credits

The U.S. District Court for the Southern District of Ohio issued an opinion in U.S. v. Quebe. The case is an erroneous refund claim suit in which the government is seeking to recoup refunds paid ...
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IRS Says Internal Use Software Regs Apply in Total

The IRS issued CCA 201650012, which addresses the pre-2015 research tax credit regulations that apply to internal use software ("IUS"). This guidance addresses the question as to whether the two prior IUS regulations, which the ...
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