In Procter & Gamble Co. v. United States, No. 1:08-cv-00608-TSB (Jun. 25, 2010), the District Court for the Southern District of Ohio concluded that the taxpayer did not have to include gross receipts from sales to a controlled foreign corporation in computing its research tax credit. The implications of this conclusion require some further thought.
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Tags: research and experimentation, research tax credit
Posted in Federal R&D Tax Credit News • Comments Off
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”) [...]
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Tags: business component, R&D tax credit, research and experimentation, research tax credit
Posted in R&D Tax Credit Court Cases • Comments Off
Why read about the R&D tax credit on the web, when you can buy the book?