News & Analysis as of

Research and Development Tax Credits

Morgan Lewis

New Section 174A Restores Domestic R&E Deductibility, but Other Changes Bring Mixed Results

Morgan Lewis on

President Donald Trump signed into law the One Big Beautiful Bill Act on July 4, 2025. Among many other provisions, this bill permits taxpayers to deduct domestic research and experimentation (R&E) expenditures under new...more

Goodwin

One Big Beautiful Bill Act - Tax Highlights related to Research and Experimental Expenditures, Qualified Small Business Stock and...

Goodwin on

On July 4, 2025, the One Big Beautiful Bill Act (OBBB) was signed into law. The OBBB extends various expiring tax provisions from the Tax Cuts and Jobs Act (TCJA) and introduces a variety of other substantial tax law changes....more

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

Goodwin

One Big Beautiful Bill Act - Tax Implications for Life Sciences Industry

Goodwin on

On July 3, 2025 Congress passed, and on July 4, 2025 President Trump signed into law, the One Big Beautiful Bill Act (OBBB), which extends various expiring tax provisions from the Tax Cuts and Jobs Act and introduces a...more

Miller Canfield

Business Tax Updates in the One Big Beautiful Bill

Miller Canfield on

The One Big Beautiful Bill creates and/or modifies a number of tax rules that impact taxation of business income, including the permanent extension of the 20% pass-through deduction under Section 199A and the return of full...more

Fenwick & West LLP

House Reconciliation Bill Would Restore Expensing for Domestic R&D Prospectively

Fenwick & West LLP on

On May 22, 2025, the U.S. House of Representatives passed a reconciliation bill (commonly referred to as the “One Big Beautiful Bill”), which would restore expensing for domestic research and development expenses incurred in...more

Bradley Arant Boult Cummings LLP

Alabama Legislature Wraps Up Productive Session on Business Tax Bills

The Alabama Legislature adjourned sine die near midnight on May 14, 2025, with the final legislative meeting day bogged down with filibusters by certain senators. Fortunately, a spate of tax bills had already passed both the...more

Mintz - Tax Viewpoints

Canada Elects 2025: Tax Policies Poised to Shape Canada’s Innovation Economy

In a historic election, given the backdrop of rising tensions between Canada and the US, Canadians elected Mark Carney and his Liberal party on April 28, 2025. Although the platform released by the Liberals (the Liberal...more

Blake, Cassels & Graydon LLP

Budget 2025-2026 du Québec : Points saillants en matière de fiscalité

Le 25 mars 2025, le ministre des Finances du Québec, Eric Girard, a déposé le budget 2025-2026 du Québec (le « budget 2025-2026 »). Intitulé Pour un Québec fort, ce budget est axé sur des investissements ayant pour but...more

Blake, Cassels & Graydon LLP

Select Tax Highlights of the 2025-2026 Quebec Budget

On March 25, 2025, Quebec’s Minister of Finance, Eric Girard, tabled Quebec’s 2025-2026 Budget. This year’s budget, titled For a Strong Québec, is focused on investments to help Quebecers build a strong economy and contains...more

Miller Canfield

Are Wages for Research Credit Purposes Limited to “Reasonableness?”

Miller Canfield on

Smith v. Commissioner, a pending research credit case in the United States Tax Court, presents an issue of first impression: Is a partner’s self-employment income in a partnership allowable as a qualified research expense...more

Dentons

Iowa Tax Credit Overhaul: What A New Bill Could Mean for Venture Investment, Job Growth, and R&D

Dentons on

The Iowa Economic Development Authority (“IEDA”) recently unveiled its bill (HSB 305 and SSB 1205) to overhaul Iowa’s tax credit system. The bill is expected to go through the legislative process in both chambers soon for the...more

Miller Canfield

Comments Solicited on Michigan Research Credit Draft Notice

Miller Canfield on

The Michigan Department of Treasury released a draft of a notice regarding the new research and development credit. ...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

Bodman

Michigan Enacts Research and Development Tax Credit

Bodman on

On January 13, 2025, Michigan Governor Gretchen Whitmer signed legislation (Michigan House Bill No. 5100) establishing a research and development tax credit (the “Michigan R&D Tax Credit”) in Michigan effective for tax years...more

Mintz - Tax Viewpoints

Canada’s Fall Economic Statement: A Silver Lining for Innovators Amidst the Chaos

Mintz - Tax Viewpoints on

On a day where the only thing Canadians could talk about was the resignation of the then finance minister on the date of the delivery of the government’s 2024 Fall Economic Statement (FES 2024) and the chaos that ensued, some...more

Baker Donelson

Opportunities for U.S. Manufacturers Under the Second Trump Administration

Baker Donelson on

Expanding on our prior alert, the next administration is expected to implement economic policies that will present significant opportunities for companies who make or want to make their products in the United States with...more

Miller Canfield

Michigan Will Grant a Refundable Research and Development Income Tax Credit Beginning in 2025

Miller Canfield on

HB 5100 and HB 5101, as passed by the Michigan House of Representatives and Senate, and to be signed by Governor Gretchen Whitmer, provide a new income tax credit. For tax years beginning on and after January 1, 2025,...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

Cohen & Gresser LLP

HMRC R&D Fraud Arrests: A New Era for Tax Enforcement?

Cohen & Gresser LLP on

On 30 October 2024, the Government published its highly anticipated Autumn Budget 2024 (the “Budget”). Among measures promised to “fix the foundations of the economy” is the Government’s commitment to implement “the most...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

Proposed bill aims to postpone TCJA limits on business incentives

Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more

ArentFox Schiff

Because . . . We Said So: Congressional Taxwriters Propose Tax Deal Including Significant Modifications to Employee Retention...

ArentFox Schiff on

Yesterday, the chairmen of the Senate Finance Committee and the House Ways and Means Committee introduced The Tax Relief for American Families and Workers Act of 2024 (the Act), which proposes changes to the child tax credit,...more

Pillsbury - SeeSalt Blog

California Credit Claim Denials – California Office of Tax Appeals Issues Two Opinions Rejecting Taxpayers’ Submitted Evidence to...

The California Office of Tax Appeals (OTA) recently issued two opinions addressing the burden of proof taxpayers must meet to substantiate entitlement to California’s research and development (R&D) tax credit for qualified...more

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