By Angela Jackson This is the most recent R&D case before the U.S. Tax Court which was ruled in favor of the Commissioner and disallowed 100% of Siemer Milling’s 2011 and 2012 Research and Development (R&D) tax credit under Section 41. Siemer’s claim was disallowed for not providing adequate supporting evidence to demonstrate its process […]
Late last year a Research and Development case highlighted the importance of understanding the subtleties of qualifying software R&D claims. The case, the United States of America vs. Davenport, Civil Action No.: 3:09-CV-2455-L reached judgment in the Northern District of Texas, Dallas Division of the U.S. District Court ruled in favor of the IRS over […]
H.R. 8, “The American Taxpayer Relief Act of 2012,” passed the Senate and the House, with the President signing the bill on January 3, 2013. There were a number of business and energy tax extensions in the bill that included among others the extension and modification of the research (R&E) credit. The R&E credit has […]
Our last article focused on new EPA regulations that are prompting significant research and development activities for most utilities. We’ve also written in the past regarding the expected impact of the Japanese accident at Fukushima on the Nuclear Industry and new R&D that will be performed. Here’s an update on expected areas that will require […]
The Environmental Protection Agency (EPA) has a number of proposed regulations; however, two in particular will present significant R&D opportunities for a number of utilities. With the addition of these two proposed rules, a number of electric generation facilities will be required to perform research to determine the best available technology (BAT) and/or combination of […]
“Simply put, sound research is key to determining whether extended operation beyond 60 years can be safe and, if it can, what measures need to be taken to ensure safe operation. The industry must take the lead on these research activities.” U.S. Nuclear Regulatory Commission Chairman, The Honorable Gregory B. Jaczko[1] Although 61 nuclear plants […]
U.S. Senator Kirsten Gillibrand announced a new proposal to spur innovation and job creation through the simplification, expansion, and make permanent the Research and Development (R&D) Tax Credit. Per Sen. Gillibrand’s Press Release on January 28th, expanding the R&D Tax Credit would create more than 162,000 jobs nationwide, according to the Information Technology and Innovation […]
As you are likely aware, the Research and Development (R&D) Tax Credit has yet to be renewed for the 2010 tax year. Historically, the tax credit has expired and been retroactively renewed five times in its brief history. While there are no certainties, it is highly likely that the R&D Tax Credit will be renewed […]
As first reported in the New York Times, President Obama is expected to ask Congress to increase from 14 to 17 percent the Alternative Simplified Credit percentage. Additionally a White House official said Sunday, that President Obama is expected to ask Congress to permanently extend research and development tax credits for businesses in an effort […]
On June 25, 2010, the U.S. District Court ruled on The Proctor & Gamble Company (P&G) vs. United States of America in favor of P&G. P&G and the IRS have had a long-standing accepted method on Gross Receipts computation as it relates to the Section 41 credit determination. Historically, the accepted method was to treat […]