Treatment of Capitalized R&D Costs Under Section 174 on a Disposition of Intellectual Property
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide attorneys and tax professionals guidance on the treatment of capitalized R&D costs under new Section 174. The panel will discuss key issues taxpayers and tax practitioners have faced as a result of amendments to Section 174, the impact on related expenses and basis, special rules for treatment of R&D expenses on a disposition of the asset, special issues for contract R&D service providers, and other key issues. The panel will also provide insight on issues stemming from the recovery of capitalized costs, taxable dispositions, tax-free transfers of intellectual property, and other key items.
Outline
- Section 174 legislation update
- R&D costs
- Implementing Section 174 capitalization requirements
- Does Section 174 apply to contract R&D?
- Issues stemming from recovery of capitalized costs under Section 174
- Taxable dispositions
- Tax-free transfers of IP
- Best practices
Benefits
The panel will cover these and other key issues:
- What costs are included in the definition of R&D?
- What issues are presented when implementing Section 174 capitalization requirements?
- Does Section 174 apply to contract R&D service providers?
- What is the impact on taxable dispositions, reporting, and planning?
- How are capitalized expenses treated if the assets are transferred tax free?
Faculty
Ariel Love
Attorney
Fenwick & West
Ms. Love focuses her practice on a broad variety of domestic and international tax planning and tax controversy... | Read More
Ms. Love focuses her practice on a broad variety of domestic and international tax planning and tax controversy matters. She regularly represents clients from a diverse set of industries and geographic areas, including a number of Fortune 500 companies.
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Kunaal Patel, CPA
Partner
Moss Adams
Mr. Patel has practiced public accounting since 2007. He primarily assists multi-national companies in the technology,... | Read More
Mr. Patel has practiced public accounting since 2007. He primarily assists multi-national companies in the technology, life sciences, and entertainment industries. Mr. Patel experience includes federal, state, and international tax compliance; ASC 740 (formerly known as FAS 109); and provision preparation and review. He also provides general tax planning for start-up, emerging growth, and publicly traded companies, and has successfully supported clients undergoing IRS and foreign audit investigations. Prior to joining Moss Adams, Mr. Patel spent six years working in federal tax at two Big Four firms.
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William R. Skinner
Partner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.
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