Why read about the R&D tax credit on the web, when you can buy the book?
MEMORANDUM OPINION WILLIAM L. STANDISH, District Judge. These suits focus on the efforts of Plaintiffs Bayer Corporation, its subsidiaries, and Bayer-Onyx (collectively, “Bayer”) to recover some $50 million in federal income tax payments to which Plaintiffs argue they are entitled as qualified research tax credits under 26 U.S.C. § 41. Now pending before the Court [...]
Feb 22nd, 2010
The government recently issued Technical Advice Memorandum 201006027, applying the R&D tax credit rules for acquiring and disposing of business assets in the context of the I.R.C. § 963 possessions tax credit. This now defunct possession tax credit rewarded taxpayer’s for operating businesses in U.S. possessions, such as Puerto Rico. It incorporates the R&D tax [...]
Feb 19th, 2010
In R.H. Donnelley Corp. v. United States, No. 5:08-cv-00501 (ED NC 2010), the court addressed a unique situation involving the carryback of an R&D tax credit. The facts were as follows. The R&D tax credit was for tax year 1994. The taxpayer’s 1994 tax return was audited. No changes were made as a result of [...]
DAVID C. GODBEY, District Judge. This matter came on for trial before the Court on March 31, 2009 through April 3, 2009. This Order constitutes the Court’s findings of fact and conclusions of law. I. INTRODUCTION This is a tax refund suit. Trinity Industries, Inc. (“Trinity”) seeks a refund for certain qualified research expenditure (“QRE”) [...]