News & Analysis as of

Tax Credits › Tax Deductions › Tax Court

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

Stikeman Elliott LLP

Tax Court of Canada Denies GST/HST Input Tax Credit Claims in Connection with a Settlement Payment

Stikeman Elliott LLP on

In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...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

Freeman Law

Tax Court in Brief | Moore v. Comm’r | Research Credit and Computation of Research Expenses under Section 41(a)

Freeman Law on

Summary: Petitioner Gayla Moore was the sole owner of Nevco, Inc. (Nevco), a subchapter S corporation, during the tax years in issue (2014 and 2015). Nevco claimed the section 411 credit for increasing research activities...more

Freeman Law

The Tax Court in Brief - August 2021 #4

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more

Miller Canfield

Tax Court's Scorched-Earth Opinion Disallows Research Credits for Dress Design Activities

Miller Canfield on

For practitioners advancing research credit claims, a recent Tax Court case is of concern because it said more than was necessary to reject the taxpayer's claim. The Commissioner may seize upon dicta in the opinion to...more

Partridge Snow & Hahn LLP

Tax Court Confirms That Cannabis Businesses Cannot Take Advantage of Certain Tax Breaks Other Businesses Use

Partridge Snow & Hahn LLP on

One of the most frustrating issues facing the US’s burgeoning cannabis industry has been the inequitable tax treatment that cannabis businesses face as compared to other industries. The IRS’s guidance for one section of the...more

Freeman Law

The Tax Court in Brief - February 2021 #2

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of February 8 – February 12, 2021 - BM Construction v....more

8 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:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide