News & Analysis as of

Internal Revenue Service Research and Development Corporate Taxes

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
BakerHostetler

Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more

Eversheds Sutherland (US) LLP

House confirms favorable modifications to three key business tax provisions

On May 12, 2025, the Republicans on the House Committee on Ways and Means released a draft bill showing their tax plan for the budget reconciliation legislation. The legislation will likely undergo significant changes as it...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

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

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

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

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

A&O Shearman

IRS Permits First Spin-off of R&D Intensive Business With No Pre Spin-off Income

A&O Shearman on

On February 28, 2020, the Internal Revenue Service (the “IRS”) released PLR 202009002, the first private letter ruling that will potentially permit a tax-free spin-off of a research and development (“R&D”) intensive business...more

Wilson Sonsini Goodrich & Rosati

IRS May Relax Collection of Income Prong of Section 355 Active Trade or Business Test for R&D Companies

On September 25, 2018, the Internal Revenue Service (the IRS) released a statement announcing a study of the "active trade or business" test for tax-free spin-offs under Section 355 (the ATB Test), as applied to...more

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