Navigating IRS Scrutiny of R&D Tax Credits: Qualified Research Activity, Expenses, Research Credit Claims Audits
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will guide tax professionals and advisers on navigating IRS scrutiny and challenges to the R&D tax credit for small and large businesses and international taxpayers. The panel will discuss the recent IRS crackdown on documentation of research credit claims, managing IRS audits, qualified research activities (QRAs) and qualified research expenses (QREs), safe harbor for certain taxpayers, and techniques to assist in documenting and claiming R&D credits.
Outline
- Recent IRS guidance for the R&D tax credit
- Determining QRAs
- IRS regulations on QRA calculations
- Sampling and allocation methods for QREs
- Documentation and substantiation of credit claim
- Applying for credits against AMT or payroll tax liability
Benefits
The panel will discuss these and other important topics:
- Recent IRS guidance for claiming the R&D tax credit
- The four-part test to determine whether an activity can be considered a QRA for purposes of claiming a Section 41 R&D credit
- Documentation and substantiation requirements
- Sampling strategies for including wage QREs and other indirect costs in the credit calculation
- Best practices for businesses claiming a Section 41 R&D credit
Faculty
Sandra R. Brown
Principal
Hochman Salkin Toscher Perez
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations,... | Read More
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.
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Dennis L. Perez
Principal
Hochman Salkin Toscher Perez
Mr. Perez has extensive experience in the representation of clients in civil and criminal tax litigation and in tax... | Read More
Mr. Perez has extensive experience in the representation of clients in civil and criminal tax litigation and in tax disputes and controversies before the Internal Revenue Service and all the California taxing agencies. He was formerly a senior trial attorney with District Counsel, Internal Revenue Service, in Los Angeles, California. Mr. Perez is a Certified Tax Specialist, California State Bar Board of Certification and is also a Fellow of the American College of Tax Counsel. He frequently lectures on advanced civil and criminal tax topics at seminars and before national, state and local bar associations and accountancy groups. He is a co-author of the BNA Portfolio, Tax Crimes, has served as the Chair of the Los Angeles Lawyer Magazine Editorial Board and is the first recipient of the Los Angeles Lawyer Sam Lipsman Service Award for outstanding service to the Los Angeles Lawyer Magazine. He is past Chair of the Tax Procedure and Litigation Committees of the Taxation Sections of the State Bar of California and the Los Angeles County Bar Association. Mr. Perez is past President of the Alumni Board for the UCLA School of Law and has served as an Adjunct Professor, Golden Gate University, Graduate School of Taxation.
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Cory Stigile
Principal
Hochman Salkin Toscher Perez
Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation... | Read More
Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state tax controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). Mr. Stigile frequently writes and lectures on topics involving taxation.
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