The price of a forever stamp increased from $0.58 to $0.63 on January 1, 2023. A tax pro posted this fact as a public service announcement on Facebook. Of course, tax pros being tax pros, someone chimed in, “Do I have to recognize a capital gain upon disposition of my forever stamp?” And of course, someone (me) felt obliged to answer, “It depends.” A direct message followed this bit of tax drollery on Twitter that says, “In theory, if I’m holding stamps as an investment, they would be a capital asset.” And so it begins…
Reassessing R&D Structures After the Section 174 Changes
Ted Stotzer
Recent changes to the tax treatment of research and experimental (“R&E”) expenditures may warrant a fresh look at existing intellectual property (“IP”) and research and development (“R&D”) structures. This article examines whether taxpayers should revisit decisions regarding the location of R&D activities, IP ownership, contract R&D arrangements, and related transfer pricing policies in light of the evolving legislative landscape, and how the interaction of Sections 174, 168(k), 59(e), and 163(j) can be used to calibrate a tax-efficient result.
