(a) Controlled group of corporations; trades or businesses under common control—(1) In general. In determining the amount of research credit allowed with respect to a trade or business that at the end of its taxable year is a member of a controlled group of corporations or a member of a group of trades or businesses [...]
The ‘R&D Tax Credit Code & Regs’ Category
Sec 1.41-5A Basic research for taxable years beginning before January 1, 1987
(a) In general. The amount expended for basic research within the meaning of section 30(e) (before amended by the Tax Reform Act of 1986) equals the sum of money plus the taxpayer’s basis in tangible property (other than land) transferred for use in the performance of basic research.
(b) Trade or business requirement. Any amount treated [...]
Sec 1.41-4A Qualified research for taxable years beginning before January 1, 1986
(a) General rule. Except as otherwise provided in section 30(d) (as that section read before amendment by the Tax Reform Act of 1986) and in this section, the term “qualified research” means research, expenditures for which would be research and experimental expenditures within the meaning of section 174. Expenditures that are ineligible for the section [...]
Sec 1.41-1 Credit for increasing research activities
(a) Amount of credit. The amount of a taxpayer’s credit is determined under section 41(a). For taxable years beginning after June 30, 1996, and at the election of the taxpayer, the portion of the credit determined under section 41(a)(1) may be calculated using the alternative incremental credit set forth in section 41(c)(4).
(b) Introduction to [...]


