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Research & Development

Temporary Regs on allocation of controlled groups’ research credits follow 2013 notice

Temporary Regs on allocation of controlled groups’ research credits follow 2013 notice

T.D. 9717, 04/02/2015; Reg. § 1.41-0, Reg. § 1.41-6, Reg. § 1.41-6T , Reg. § 1.45G-0, Reg. § 1.45G-1, Reg. § 1.45G-1T , Reg. § 1.280C-4, Reg. § 1.280C-4T; Preamble to Prop Reg04/02/2015; Prop Reg § 1.41-6 , Prop Reg § 1.45G-1, Prop Reg § 1.280C-4 IRS has issued temporary regs which provide rules for […]

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Court directed to resolve taxpayer’s consistency rule argument for a larger research credit

Court directed to resolve taxpayer’s consistency rule argument for a larger research credit

Trinity Industries Inc., (CA 5 07/02/2014) 114 AFTR 2d ¶2014-5026 The Court of Appeals for the Fifth Circuit has largely affirmed a district court’s determinations with respect to the amount of research credit that a corporation that designed and built boats was entitled to for two tax years, including the court’s decision to not use […]

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2011 Credit for Increasing Research Activities (Corporations)

2011 Credit for Increasing Research Activities (Corporations)

2011 Credit for Increasing Research Activities (Corporations) Tables presenting statistics from Form 6765, Credit for Increasing Research Activities, for the regular credit and the alternative simplified credit, by industrial sectors and manufacturing groups, for Tax Year 2011, are available on Tax Stats. These tables show returns of active corporations, other than Forms 1120S, 1120-REIT and […]

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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