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Documentation has become a key component in the fight for taxpayers to sustain research credits in the US. In a recent court case, Trinity v. US, the court allowed testimony and high-level financial information to estimate the expenditures related to qualified research projects.
A long standing definition of supply costs was redefined in favor of taxpayers as a result of TG Missouri v. Commissioner. The IRS has held that supply costs taken as part of qualified research expenses for purposes of the R&D tax credit can not be "of a character subject to the allowance for depreciation."While this definition is defined in the IRS Regulations, the court ruled that the character of the supply costs needs to be evaluated in the hands of the taxpayer rather than in an absolute fashion. For a more complete discussion dowload our white paper summary of TG Missouri v Commissioner.
With the release of the new proposed regulations (published on 1/20/2015 in the Federal Register) on the treatment of internal use software, we may have some clarity on the proper treatment of software development that has, in the past, been inconsistent and heavy-handed.
Download our free pricing guide to find out how much an R&D study costs.
With the repeal of extra-territorial income exclusion (“ETI”), the Service began to see the reemergence of the domestic international sales corporation (“DISC”) in the form of an interest charge DISC (“IC-DISC”).
This guide covers a general overview of the DISC, the DISC law and major concepts, a Code and Regulation section approach to some of the major concepts of the DISC, audit techniques and more.
Congressional intent has always been the cornerstone for how a law enacted by Congress is then administered by Treasury (aka The Internal Revenue Service). Within the depths and detail of the Research and Development Tax Credit, following and administering congressional intent has always been a challenge for the IRS (and for taxpayers, for that matter).
The information contained in this whitepaper is helpful as you analyze the software development projects at issue to evaluate whether they will meet the stringent guidelines of the Higher Threshold of Innovation Test.
There are many benefits of R&D tax credits such as the increased cash flow for operations and growth, and the fact that it applies to a wide range of industries are a just a few. Before you dive into determining your R&D tax credits, it's important to learn the basics.
Download our free slides that will break down the basics of the R&D tax credit.
Tax incentives such as the IC-DISC are critical to maximizing cash flow and success for new ventures. Learn what an IC-DISC actually is, the structure of them, the requirements to be an IC-DISC, more benefits of them and who can qualify download our free slides.
Service DescriptionTaxpayers are filing claims for the credit for increasing research activities (research credit) under Internal Revenue Code (I.R.C.) § 41  often at the end of an examination cycle, which is requiring the expenditure of additional audit resources often at the expense of other significant audit issues.
Download our free guide for more information on audit techniques for examining RC Claim, RC claim examination tools and much more.
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