IRS Pens Final Rules On Controlled Group Research Credits

Law360, New York (April 2, 2015, 3:22 PM EDT) -- Individual members of a controlled group of corporations will no longer need to calculate the value of the research credit they would get on their own when the group claims the credit, the Internal Revenue Service said in regulations released Thursday.

Under the rules, the group research credit is allocated to members of the group based on their proportional share of qualified research expenditures. Previous regulations required the credit to be allocated according to each member's stand-alone entity credit in some cases.

The American Taxpayer Relief Act of 2012 amended section 41 of the Tax Code to "provide that the group...

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