The Internal Revenue Service (hereinafter “IRS”; or “the Service”) recently issued on September 14th of 2016 an Audit Techniques Guide (hereinafter “ATG”) governing Tangible Property Regulation Compliance (hereinafter “TPR Compliance”).
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The Protecting Americans from Tax Hikes Act of 2015 (hereinafter the “PATH Act”) significantly enhanced the Federal-Level R&D Tax Credit Program (hereinafter “RTC Program”) under I.R.C. § 41 on a myriad of levels for both eligible “Small Businesses” and “Start-Up Companies”. More specifically, the enhanced RTC Program has been considerably restructured for these aforementioned eligible companies to now:
A properly designed and implemented Construction Tax Planning engagement will proactively identify additional tax savings related to new and/or planned construction projects. It should be duly noted that a Construction Tax Planning engagement should not be confused with a Cost Segregation engagement as there are several noteworthy differences between a Cost Segregation Engagement and a Construction Tax Planning Engagement.
The Protecting Americans from Tax Hikes Act of 2015 (hereinafter the “PATH Act”) significantly enhanced the Federal-Level R&D Tax Credit Program (hereinafter “RTC Program”) under I.R.C. § 41 on a myriad of levels for both eligible “Small Businesses” and eligible “Start-Up Companies”. More specifically, the enhanced RTC Program has been considerably restructured for these aforementioned eligible companies to now:
On May 5th, the Internal Revenue Service (hereinafter the “Service”) issued Rev. Proc. 2016-29, which outlines automatic accounting method changes and provides administrative procedures for electing them. Consequently, filers of Form 3115 entitled “Application for Change in Accounting Method” filed on or after May 5, 2016 must now follow this updated form of administrative authority. As it should be duly recalled, a revenue procedure is a statement of procedure that affects the rights or duties of taxpayers or other members of the public under the Internal Revenue Code (hereinafter the “Code”). Similar to Revenue Rulings, Revenue Procedures are less authoritative than Temporary and Final Treasury Regulations. Regardless, Revenue Procedures are binding on the Service and taxpayers alike and should be adhered to for purposes of assessing tax return filing positions under the Code and Circular 230.
Your Practical Guide to Movie Production Tax Incentives
Introduction
Whether you’re a publicly held movie studio conglomerate producing and distributing substantial numbers of films annually commanding significant shares of box office revenues worldwide or an independent filmmaker, movie production tax incentives should certainly be considered and incorporated into the tax planning process to properly tax effect the cost of filmmaking. Read More
The Internal Revenue Service (hereinafter the “Service”) issued on March 24 of 2016 their Announcement 2016-14 addressing the transition period implementation dates in connection with the recently revised Form 3115 entitled “Application for Change in Accounting Method” which was most recently revised and released to the public in December of 2015. This presents a paradigm shift as while most tax forms and publications are updated annually, this was the first update to Form 3115 since December of 2009. Read More
Introduction
The Internal Revenue Service (hereinafter the “Service”) issued on March 24 of 2016 their Announcement 2016-14 addressing the transition period implementation dates in connection with the recently revised Form 3115 entitled “Application for Change in Accounting Method” which was most recently revised and released to the public in December of 2015. This presents a paradigm shift as while most tax forms and publications are updated annually, this was the first update to Form 3115 since December of 2009. Read More
History of the R&D Tax Credit Program
The Federal-Level Research and Development Tax Credit Program (hereinafter “RTCP” or “RTC”) was originally enacted into the Internal Revenue Code (hereinafter “the Code”) through the Economic Recovery Tax Act of 1981 as a temporary provision of the Code at a time when research and development jobs were significantly declining throughout the United States. Notably, the RTCP was introduced into the Code to encourage business entity taxpayers to invest in Read More
On December 18th of 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (hereinafter the “PATH Act”) that significantly enhanced the Federal-Level R&D Tax Credit Program (hereinafter “RTC Program”) under I.R.C. § 41 on a myriad of levels for both eligible “Small Businesses” and eligible “Start-Up Companies”. More specifically, the enhanced RTC Program has been considerably restructured for these aforementioned companies to now:
• Allow eligible “Small Businesses” (i.e., $50 million or less in gross receipts) to claim the credit against the Alternative Minimum Tax (hereinafter “AMT”) for tax years beginning after December 31, 2015; and Read More
On December 18th of 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (hereinafter the “PATH Act”) which expanded the scope and application of the I.R.C. § 181 deduction for Qualified Film and Television Production expenditures to now encompass Live-Theatrical Productions. The PATH Act also extended this highly advantageous tax incentive through December 31, 2016.
The PATH Act truly enables a level playing field between live-theatrical productions and film and television productions in connection to the tax incentives available for the entertainment industry. Robert E. Wankel, Chairman of The Broadway League in a prepared statement indicated: “The Broadway and Touring Broadway industries have a combined economic impact of more than $15 billion dollars on the nation’s economy and employ tens of thousands of people in the U.S. and around the world, yet we are still very much made up of small businesses that actively seek financing from individual investors. This relatively small Read More
On December 18th of 2015, President Obama signed into law a sweeping $1.14 trillion dollar funding bill that will keep the federal government operating through September 30th of 2016. In connection to the tax aspects of this comprehensive and pivotal legislation, the Protecting Americans from Tax Hikes Act of 2015 (hereinafter the “PATH Act”) accomplished considerably more than the typical tax-extenders legislation passed in previous years and truly signifies a dynamic paradigm shift as the PATH Act makes permanent over twenty leading tax incentives while extending other tax incentives over either a five year period or a two year period.
In particular, the PATH Act meaningfully enhanced the R&D Tax Credit Program (hereinafter “RTC program”) on a myriad of levels. As an overview, the RTC program was initially added to the U.S. Internal Revenue Code (hereinafter the “Code”) in 1981 through the Economic Recovery Tax Act of 1981 as a temporary provision of the Code. The RTC program had most recently expired on December 31, 2014. A tremendous paradigm shift to the RTC program was made possible through the PATH Act which not only renewed the RTC retroactively for all of calendar year 2015 but most importantly made the RTC program permanent. In addition, the enhanced RTC program has been considerably restructured to: Read More
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