News & Analysis as of

Tax Deductions Research and Development

Miller Canfield

Some Research Credit Good News and Potentially Much Bad News

Miller Canfield on

Over an objection by the IRS, the Tax Court recently ruled in Kapur v. Commissioner that it could limit discovery and permit statistical sampling of voluminous data related to a claimed research credit. The court refused,...more

Gray Reed

Federal Income Taxation of Intellectual Property Development and Cost Recovery

Gray Reed on

Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

Holland & Knight LLP

R&D Considerations in the Time of Non-Deductibility

Holland & Knight LLP on

The close of 2022 means family gatherings, holiday fun and one step closer to the end of research and development (R&D) expense current deductibility. Prior to the Tax Cuts and Jobs Act (TCJA), Internal Revenue Code Section...more

Freeman Law

The Research and Development Credit – Section 41

Freeman Law on

Taxpayers are always interested in whether certain expenditures qualify as tax deductions. But many taxpayers often forget that expenditures may alternatively qualify for various tax credits. And all things being equal,...more

Orrick, Herrington & Sutcliffe LLP

Super deduzione per i costi di R&S e credito d’imposta – le novità del Decreto Fiscale

È prevista l'abrogazione del Patent Box e l'introduzione di una nuova opzione per la maggiore deducibilità del 90% dei costi di ricerca e sviluppo sui beni immateriali alternativa al credito d’imposta per attività di ricerca,...more

Orrick, Herrington & Sutcliffe LLP

Super Deduction for R&D Costs and Tax Credit - What's New in the Tax Decree

The tax decree October 21, 2021 no.146 provided the abolishing of the Patent Box regime and the introduction of a new optional regime providing an extra deduction (for Corporate income tax purposes as well as for the Regional...more

Eversheds Sutherland (US) LLP

The devil is in the details: Final infrastructure framework announced, fingers crossed for continued R&E deductibility

Democratic leadership announced today that an agreement has been reached to fund the pending infrastructure and budget reconciliation measures. There does not appear to be any agreement regarding which specific tax measures...more

Miller Canfield

The Government's Use of Procedural Hurdles to Disallow Research Credit Refund Claims

Miller Canfield on

In two recent cases, the IRS has tried to defeat research credit refund claims on procedural grounds, rather than simply litigating whether the substantive nature of the asserted research meets the requirements of section 41...more

Orrick, Herrington & Sutcliffe LLP

Bilancio di Previsione dello Stato per l'anno finanziario 2020

(Legge 27 dicembre 2019, n. 160 pubblicata in Gazzetta Ufficiale serie generale 304 del 30 dicembre 2019). ...more

Mintz

Overview of Recent U.S. Tax Reform Part I – Certain Significant Changes Impacting C-Corporations

Mintz on

On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax...more

Proskauer - Tax Talks

Potential for Tax Reform in 2017: Insight from Proposals of the President-Elect and Congressional Republicans

Proskauer - Tax Talks on

In the U.S. general election held on November 8, 2016, Donald J. Trump was elected to become the 45th President of the United States. Republicans also retained their majorities in both the U.S. House of Representatives and...more

Orrick, Herrington & Sutcliffe LLP

Patent Box – Ultimi Aggiornamenti Dall’Agenzia Delle Entrate

As known the cd. "Patent Box" allows companies carrying out activities Research & Development to opt, as from the tax in 2015, for a taxation regime facilitated the income generated from the direct exploitation or indirect...more

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