Just in – the IRS dropped a hot alert about the Employee Retention Credit (ERC), and it's time to pay attention . With the March 22, 2024, deadline creeping up for the ERC Voluntary Disclosure Program, it's crucial for those who mistakenly filed a claim to take action. This program lets businesses repay just 80% of the claimed amount, so it's a chance to make things right. If your clients filed a claim that's still in the pipeline, it's time for a double-check. Review the guidelines ASAP and withdraw the claim if it doesn't pass muster.
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.
