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Qualified Research Expenses (QREs)

Court of Appeals 9th Circuit reverses; home mortgage interest deduction limits apply per taxpayer

Court of Appeals 9th Circuit reverses; home mortgage interest deduction limits apply per taxpayer

Voss v. Comm., (CA 9 8/7/2015) 116 AFTR 2d ¶ 2015-5128 A divided Court of Appeals for the Ninth Circuit, reversing a Tax Court decision, has concluded that the Code Sec. 163(h)(3) limitations ($1 million of acquisition indebtedness and $100,000 of home equity indebtedness) are applied on a per-individual basis, and not a per-residence basis. […]

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Condominium’s Tax-Equivalency Payments Deductible as Real Estate Taxes

Condominium’s Tax-Equivalency Payments Deductible as Real Estate Taxes

PLR 201452015   IRS has privately ruled that payments in lieu of taxes (PILOT), commonly referred to as tax equivalency payments, made by a condominium developer to its landlord, a governmental fund, can be deducted as real estate taxes under Code Sec. 164. By extension, when the developer sells condominium units, each unit buyer also […]

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Tax Court OKs most of company’s qualified research expenses for research credit

Tax Court OKs most of company’s qualified research expenses for research credit

Suder, TC Memo 2014-201 In consolidated cases, the Tax Court has concluded that expenses for 11 out of the 12 projects of a company designing telephone systems satisfied the 4-part test for qualified research expenses (QREs) for purposes of claiming the Code Sec. 41 research credit. However, the Court also found that the wages of […]

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Final reg on deductible R&E costs relaxes rules for tangible property development

Final reg on deductible R&E costs relaxes rules for tangible property development

T.D. 9680, 07/18/2014; Reg. § 1.174-2 IRS has issued a final reg that amends the definition of research and experimental expenditures under Code Sec. 174. The reg, which generally adopts a proposed reg issued last fall with certain modifications, clarifies and liberalizes some existing restrictions on the treatment of amounts paid or incurred in connection […]

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Amended regulations allow alternative simplified research credit election on amended returns

Amended regulations allow alternative simplified research credit election on amended returns

T.D. 9666, 06/02/2014; Reg. § 1.41-9T, Reg. § 1.41-9; Preamble to Prop Reg 06/02/2014; Prop Reg § 1.41-9. IRS has issued temporary and proposed regs that amend existing final regs to allow taxpayers that did not claim a research credit on a previously filed return for a given tax year to elect the alternative simplified […]

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Proposed Regulations Would Change Research Credit Calculations For Controlled Group Transactions

Proposed Regulations Would Change Research Credit Calculations For Controlled Group Transactions

IRS has issued proposed regulations that would: a) provide an exception to the general treatment of gross receipts of a foreign corporation for purposes of the calculation of a controlled group’s research credit base amount, and b) require that controlled group base amount calculations reflect the law in effect for the year that the research […]

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OECD examines effect of cross-border tax planning on R&D issues

OECD examines effect of cross-border tax planning on R&D issues

In a recent report titled “Supporting Investment in Knowledge Capital, Growth and Innovation,” the Organization for Economic Cooperation and Development (OECD) has examined the rise of “knowledge-based capital,” its contribution to economic growth, and related tax and policy concerns. Among other things, the OECD concluded that international tax policies and cross-border tax planning should be […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney