News & Analysis as of

U.S. Treasury Research and Development

Mintz - Antitrust Viewpoints

AI Provisions in Biden’s FY 2025 Budget Proposal — AI: The Washington Report

President Joe Biden’s fiscal year (FY) 2025 budget proposal includes hundreds of millions of dollars allocated towards executive branch AI efforts. The budget proposal’s AI-related provisions can be sorted into three...more

Mintz - ML Strategies

ML Strategies Outlook for 2024

Mintz - ML Strategies on

Congress — Big Agenda & Little Time - With the holidays behind us, Congress returned this week for the second half of the 118th Congress with a long list of items to address and, as the 2024 campaign season ramps up, limited...more

Eversheds Sutherland (US) LLP

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...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

Eversheds Sutherland (US) LLP

An olive branch or shot across the bow? IRS issues Notice 2023-63 providing welcome substantive Section 174 guidance

The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more

Kohrman Jackson & Krantz LLP

Maximizing What You Already Do: The Value of the Research and Development Tax Credit for Startups and Small Businesses

The Research and Development Tax Credit, formally known as the Credit for Increasing Research Activities under Section 41 of the Internal Revenue Code, has been in existence for many years to encourage companies to conduct...more

Miller Canfield

The IRS Achievement: No One Gets Research Credits

Miller Canfield on

A Treasury regulation provides that a researcher performing technological research for its customer is not entitled to federal income tax credits for the cost of the research if the researcher does not retain substantial...more

McDermott Will & Emery

Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

McDermott Will & Emery on

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more

Latham & Watkins LLP

IRS Studying Active Trade or Business Requirement for Tax-Free Spin-Offs

Latham & Watkins LLP on

The IRS is considering future guidance that could present opportunities for R&D phase businesses. In a statement issued on September 25, 2018, the Internal Revenue Service (IRS) announced that it is studying the active...more

Holland & Knight LLP

FY 2019 Administration Budget Request

Holland & Knight LLP on

President Donald Trump on February 12, 2018, submitted his budget request to Congress for Fiscal Year (FY) 2019. The President's full budget calls for approximately $4.4 trillion in total spending. Much of the budget seeks...more

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