Why read about the R&D tax credit on the web, when you can buy the book?
Apr 4th, 2007
The IRS designated the research tax credit a Tier1 issue. Tier 1 issues are those that the IRS deems to have high strategic importance to the IRS. This designation allows the IRS to commit audit resources to the issue selected. Taxpayers can expect hightened audit and scruitiny of research tax credits following this designation. More [...]
DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 LMSB Control No.: LMSB-4-0608-035 Impacted IRM 4.51.5 January 15, 2009 MEMORANDUM FOR INDUSTRY DIRECTORS DIRECTOR, FIELD SPECIALISTS DIRECTOR, PRE-FILING AND TECHNICAL GUIDANCE DIRECTOR, INTERNATIONAL COMPLIANCE, STRATEGY AND POLICY FROM: Patricia C. Chaback /s/ Patricia C. Chaback Industry Director Communications, Technology & Media SUBJECT: Tier I [...]
Like many large companies, plaintiff General Motors Corporation has an active treasury department. Its treasury department supplements the company’s other income-generating activities by investing the company’s idle cash in short-term marketable securities. These investments present special analytical problems under the Uniform Division of Income for Tax Purposes Act (UDITPA),[1] which California has adopted (Rev. & [...]
May 31st, 2006
The IRS released a new coordinated issue paper. Coordinated issue papers explain how IRS auditors, not IRS appeals officers or attorneys, will treat a particular situation. The issue paper addresses the situation where, with respect to a research tax credit, a taxpayer incurs utility expenses, such as electricity, for buildings in which qualified research activities [...]
Jan 1st, 2005
NOTE: This guide is current through the publication date. Since changes may have occurred after the publication date that would affect the accuracy of this document, no guarantees are made concerning the technical accuracy after the publication date. This Audit Techniques Guide is presented in several chapters. These chapters can be accessed and then [...]
Dec 17th, 2004
{1} The Taxation and Revenue Department of the State of New Mexico (the Department) denied an application by Team Specialty Products, Inc. (Taxpayer) for a tax credit under the Technology Jobs Tax Credit Act (the Technology Act), NMSA 1978, §§ 7-9F-1 to -12 (2000). The Department based the denial on Taxpayer’s failure to apply for [...]
Nov 23rd, 2004
The Georgia Chemistry Council, Inc. (“GCC”), a trade association representing 22 companies in the bio-tech industry, filed a declaratory judgment action against the Georgia Department of Revenue (“GDOR”) to challenge the validity of a regulation[1] which interprets the research tax credit codified in OCGA § 48-7-40.12 (“the statute”). The statute allows a tax credit of [...]
Jan 2nd, 2004
(a) Qualified research—(1) General rule. Research activities related to the development or improvement of a business component constitute qualified research only if the research activities meet all of the requirements of section 41(d)(1) and this section, and are not otherwise excluded under section 41(d)(3)(B) or (d)(4), or this section. (2) Requirements of section 41(d)(1). Research [...]
May 8th, 2003
797 N.E.2d 596 (2003) 207 Ill.2d 82 278 Ill.Dec. 1 Jack CAVENEY et al., Appellees, v. Glen L. BOWER, Director of Revenue, et al., Appellants. No. 92963. Supreme Court of Illinois. May 8, 2003. Rehearing Denied September 29, 2003. James E. Ryan, Attorney General, Springfield (Joel D. Bertocchi, Solicitor General, A. Benjamin Goldgar, Assistant Attorney [...]