An updated website launches, the economic substance codification is applied, Loper Bright Entrprs. marches on but hits the statute, and the syndicated conservation easement flood continues, as Tax Court pushes through the government shutdown. The biennial examination for non-attorney admission to Tax Court took place as scheduled.
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.
