IRS Issues Proposed Regs On Intragroup Research Credit

Law360, New York (December 12, 2013, 3:42 PM EST) -- The Internal Revenue Service released proposed regulations Thursday that address how gross receipts from transactions between domestic and foreign members of a controlled group should be computed for purposes of determining the research and development tax credit.

Transactions between members of a group are generally ignored when computing the research credit, to ensure that the computation isn't artificially increased by multiple intragroup transactions. Under the proposed regulations, the IRS will consider gross receipts from an intragroup transaction if a foreign member engages in a similar transaction...
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