News & Analysis as of

Internal Revenue Service Research and Development Tax Credits

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

Morgan Lewis - As Prescribed

Venture Philanthropy More Important Than Ever for Rare Disease Care

Private foundations providing support, resources, and advocacy for individuals and families affected by rare diseases have played an important role for more than 30 years in the advancement of treatments for rare diseases....more

Miller Canfield

Getting an Erroneous Tax Refund Case to a Jury is a Fraught Task in the Fifth Circuit

Miller Canfield on

In Grigsby v. United States, the Justice Department used discovery procedures in federal district court essentially to audit a taxpayer’s federal income tax credits for research activities. The court found that the taxpayer...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

Miller Canfield

In a Pending Research Tax Credit Case the IRS Fails to Follow Regulatory Language

Miller Canfield on

The stream of cases challenging disallowance of research tax credits continues in the Tax Court with Phoenix Design Group, Inc. v. Commissioner. The taxpayer in Phoenix Design designs mechanical, electrical, and plumbing...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

Morgan Lewis

States Lead the Way on Autonomous Vehicle Regulation as Federal Law Looms on the Horizon

Morgan Lewis on

Since 2012, the federal government has published voluntary guidance that empowers state governments to create autonomous vehicle (AV) statutory frameworks to allow and/or incentivize autonomous driving technology research and...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

Dickinson Wright

IRS Agents Tighten the Thumb Screws on R&D Credit

Dickinson Wright on

Recent taxpayer experiences suggest that IRS agents are becoming more aggressive in denying taxpayer claims of research and development tax credits through narrow construction of the so-called “substantially all” test of Code...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

12 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide