Research Tax Credit

The research tax credit is set to expire once again. Under current law, the research tax credit is only available for expenses incurred before December 31, 2009. The House Ways and Means committee has released a summary of its Tax Extenders Act of 2009, which proposes to extend several expiring tax provisions, including the research [...]

In TG Missouri Corp. v. Commissioner, 133 T.C. 13, the U.S. Tax Court recently found that property purchased from a third party qualifies as a supply expense for purposes of the research tax credit even though the taxpayer retains possession of the property. TG Missouri Corp is in the business of of manufacturing injection-molded products, [...]

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 [...]

In United States v. Beltecno, the District Court for the Western District of Washington denied the taxpayers motion for summary judgment. The case involves amended tax returns the taxpayer filed to claim research tax credits for tax years 2001 and 2002. The amended tax returns were filed in 2005 and 2006, respectively. After paying the [...]