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Practical Documentation of QRAs for the R&D Tax Credit

In the absence of records specifically created to document the research tax credit, taxpayers
often have to rely on estimates and an assortment of documents, interviews, and other evidence to substantiate expenditures that qualify for the research tax credits.

Rules Governing Internal-Use Software Are Proposed

The IRS issued long-awaited proposed regulations on what type of internal-use software qualifies for the Sec. 41 research credit. Although the new rules are proposed, not final, the IRS says it will not challenge taxpayers’ return positions that apply these rules currently.

The Orphan Drug and Research Tax Credits: The “Substantially All” Rule

The research credit under Sec. 41 (when in effect) and the orphan drug credit under Sec. 45C are sometimes available for the same expenses incurred during the development of pharmaceuticals. Understanding how the credits work and how to maximize the benefit from both of them when they are both available can reduce taxes for eligible companies.

INDIVIDUALS

Current Developments in Taxation of Individuals: Part 1

This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.