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Articles by Nathan Clukey
IRS Releases Revised Draft Form 6765 for Taxpayers Claiming Research Tax Credits
On Friday June 21, 2024, the U.S. Internal Revenue Service (IRS) released a revised draft Form 6765, the form taxpayers use to claim the I.R.C. § 41 Credit for Increasing Research Activities, and an accompanying press release.1 The revised draft modifies several of the proposed changes to Form 6765 previewed by the IRS last fall and heavily criticized by taxpayers.2 Background On Sept. 15, 2023, the IRS issued proposed changes to Form 6765 and requested feedback from interested parties.
Taxpayer-Favorable Research Tax Credit Opinion Issued in Little Sandy Coal Case
On March 7, 2023, the U.S. Court of Appeals for the Seventh Circuit issued an opinion in Little Sandy Coal v. Commissioner that will affect how the Internal Revenue Service (IRS) will audit research credit claims. While the appeals court affirmed the Tax Court’s decision in favor of the IRS, largely on the basis of a failure of proof, the case is more significant for the appeals court’s analysis, important elements of which are taxpayer-friendly.
IRS Tries To Change The Rules On Research Credit Refund Claims
To print this article, all you need is to be registered or login on Mondaq.com. On Friday, October 15, 2021, the Internal Revenue Service (IRS) Office of Chief Counsel published a memorandum (the Memorandum) purporting to answer the question of what a taxpayer must include in a claim for refund relating to the I.R.C. § 41 Credit for Increasing Research Activities.
Anti-Inversion Regulations Held to Violate Administrative Procedure Act
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Energy Newsletter - September 2017
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Tax Court Holds that IRS Cancellation of Advance Pricing Agreement was Abuse of Discretion
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IRS Rejects Investors' Claim for Refined Coal Credits in Technical Advice
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