Is the taxidermy fee for a stuffed bear deductible? If so, should I depreciate it? What would the basis and class life be for depreciation? Those are real questions asked in a group chat with some colleagues. Of course my answer was “It depends.” And, like all good tax professionals, I proceeded to ask a series of follow-up questions. And, like a good writer, that got me to thinking about all of the tax-related case law surrounding taxidermy and what it can teach us—it’s more than one might think.
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.
