The Sec. 196 deduction for unused business credits is available both where the credit carryforward period expires and when a taxpayer dies or ceases to exist.
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Credits
An early 21st century history of IRS efforts to police the R&D credit
The IRS has attempted to review and audit R&D credit claims through various techniques and strategies over the years, and the FAA harks back to recordation requirements of the late 1990s and early 2000s.
Research credit refund claims: New documentation requirements
A Chief Counsel memorandum advises that taxpayers must provide additional information to make a valid Sec. 41 research credit refund claim on an amended tax return.
The research credit: Using statistical sampling
This item discusses the Sec. 41 research credit and how statistical sampling can be used to efficiently satisfy the fourpart test that governs whether research activities qualify for the credit.
New R&D credit documentation requirements clarified
Starting Jan. 10, a Sec. 41 credit claimed on an amended return must include specific information.
Early sunset of the employee retention credit gets penalty relief
The IRS describes how employers may avoid failure-to-pay and failure-to-deposit penalties for ERC claimed or anticipated in the fourth quarter but eliminated by the Infrastructure Act.
IRS official: New R&D credit documentation applies to amended returns
The deputy commissioner of the IRS Large Business and International Division hears AICPA tax committee’s feedback on new requirements.
Certification deadline extended for work opportunity tax credit
Certain employers have until Nov. 8 to submit a required worker certification request to a designated local agency for purposes of the work opportunity credit.
New safe harbor for ERC gross-receipts calculation
Under the safe harbor, an employer can exclude certain amounts received from other coronavirus economic relief programs in determining whether it qualifies for the employee retention credit based on a decline in gross receipts.
IRS amplifies and updates ERC for second half of 2021
New guidance clarifies the application of the credit to “recovery startup businesses” and the treatment of wages paid to majority owners and their spouses.
IRS guidance denies ERC for most majority owners’ wages
The IRS’s release of Notice 2021-49 provides employers with additional guidance on issues of the employee retention credit.
Final regs. issued on qualified improvement property under FDII, GILTI
Final regulations clarify the treatment of qualified improvement property in FDII and GILTI, and foreign tax credit transition rules address post-2017 NOL carrybacks to pre-2018 tax years.
FAQs address ARPA credits
The IRS has posted two sets of FAQs that explain changes to the child and dependent care credit and to the sick and family leave credits made by the American Rescue Plan Act.
Certification deadline extended for work opportunity tax credit
Certain employers have until Nov. 8 to submit a required worker certification request to a designated local agency for purposes of the work opportunity credit.
New safe harbor for ERC gross receipts calculation
Under the safe harbor, an employer can exclude certain amounts received from other coronavirus economic relief programs in determining whether it qualifies for the employee retention credit based on a decline in gross receipts.
Guidance on claiming the ERC for third and fourth quarters of 2021
New guidance clarifies the application of the credit to “recovery startup businesses” and the treatment of wages paid to majority owners and their spouses.
Penalty relief for payroll tax deposits allows immediate use of pandemic credits
The IRS provided for penalty relief under Sec. 6656 for an employer’s failure to timely deposit certain employment taxes with the IRS to allow employers to immediately take advantage of various credits enacted in response to the COVID-19 pandemic.
IRS posts ARPA credit FAQs
The IRS has posted two sets of FAQs that explain changes to the child and dependent care credit and to the sick and family leave credits made by the American Rescue Plan Act.
IRS explains employee retention credit rules for first half of 2021
The IRS issued guidance on how to claim the employee retention credit for the first and second quarters of 2021.
How to claim the employee retention credit for the first half of 2021
The IRS issued guidance on how to claim the employee retention credit for the first and second quarters of 2021. It will issue guidance on the employee retention credit from July 1 to Dec. 31, 2021, provided in new Sec. 3134, at a later date.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
