Section 41 R&D Credits for Pass-Through Entities After Tax Reform: Maximizing Tax Credits for Research Expenditures
Impact of Lower Corporate Rates on Value of R&D Credits, Special Allocations of Credits, Section 174 Expensing
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to maximizing the benefits of the Section 41 Research and Development (R&D) Income Tax Credit, with a focus on pass-through entities (PTEs). The panel will drill down into activities that constitute qualified research activities (QRAs), and detail how changes in the 2017 tax reform law enhanced the value of the credit for many taxpayers, particularly PTEs.
Outline
- Overview of Section 41 R&D credit
- Four-part test to determine QRAs
- Documentation and substantiation of credit claim
- R&D credit considerations unique to pass-through entities
- Tax reform changes indirectly impacting the tax value of R&D credits for pass-throughs
- Lowering of corporate tax rate and impact on Section 280C(c)(3) election
- Section 199A and the R&D credit
- Implications of centralized audit regime changes on special allocations of R&D credits
- Pending changes to treatment of Section 174 expenditures
Benefits
The panel will discuss these and other relevant topics:
- Determining whether an activity can be considered a QRA for purposes of claiming a Section 41 R&D credit
- Documentation and substantiation requirements and practices from court cases
- How the 2017 tax reform change to the top corporate income tax rate enhanced the value of the Section 41 R&D credit to PTEs
- Impact of the centralized audit regime on strategies for special allocations of R&D credits
Faculty

Les Bryson
R&D Tax Credit Consultant
Endeavor Advisors
Over the last 12 years, Mr. Bryson has led the R&D department at a national tax advisory firm where he assisted... | Read More
Over the last 12 years, Mr. Bryson has led the R&D department at a national tax advisory firm where he assisted companies in capturing nearly $500mm in tax credits and incentives. He has served companies in the manufacturing, tech, pharma, architecture, engineering, agriculture, and defense industries, among others. Mr. Bryson approaches his consulting practice with the mindset of both a scientist and a trusted advisor, one of client-focused service and data-driven results.
Close
Angelique Garcia
Manager
Warner Robinson
Ms. Garcia focuses her practice on managing and implementing R&D Tax Credit studies. Previously, at a consulting... | Read More
Ms. Garcia focuses her practice on managing and implementing R&D Tax Credit studies. Previously, at a consulting firm, she led the company’s software implementation group and was published several times for her expertise in software-specific issues such as gaming and state tax incentives for digital media. Although she specializes in software technology, she implemented hundreds of R&D studies for virtually every sector of software development, from healthcare, financial trading platforms and energy management to video game development and cloud computing.
Close
Joseph C. Mandarino
Partner
Smith Gambrell & Russell
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of... | Read More
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of businesses and transactions, including experience with compliance, planning and M&A activities for partnerships, individuals and corporations. Mr. Mandarino writes and speaks extensively on a wide range of business, tax and finance topics.
Close