News & Analysis as of

Research and Development Tax Deductions 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

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

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

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

Holland & Knight LLP

R&D Considerations in the Time of Non-Deductibility

Holland & Knight LLP on

The close of 2022 means family gatherings, holiday fun and one step closer to the end of research and development (R&D) expense current deductibility. Prior to the Tax Cuts and Jobs Act (TCJA), Internal Revenue Code Section...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

Orrick, Herrington & Sutcliffe LLP

Super deduzione per i costi di R&S e credito d’imposta – le novità del Decreto Fiscale

È prevista l'abrogazione del Patent Box e l'introduzione di una nuova opzione per la maggiore deducibilità del 90% dei costi di ricerca e sviluppo sui beni immateriali alternativa al credito d’imposta per attività di ricerca,...more

Orrick, Herrington & Sutcliffe LLP

Super Deduction for R&D Costs and Tax Credit - What's New in the Tax Decree

The tax decree October 21, 2021 no.146 provided the abolishing of the Patent Box regime and the introduction of a new optional regime providing an extra deduction (for Corporate income tax purposes as well as for the Regional...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

Orrick, Herrington & Sutcliffe LLP

Bilancio di Previsione dello Stato per l'anno finanziario 2020

(Legge 27 dicembre 2019, n. 160 pubblicata in Gazzetta Ufficiale serie generale 304 del 30 dicembre 2019). ...more

Proskauer - Tax Talks

Potential for Tax Reform in 2017: Insight from Proposals of the President-Elect and Congressional Republicans

Proskauer - Tax Talks on

In the U.S. general election held on November 8, 2016, Donald J. Trump was elected to become the 45th President of the United States. Republicans also retained their majorities in both the U.S. House of Representatives and...more

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