On June 2, 2014, The Department of Treasury announced that modified treasury regulations (e.g., TD 9666) will enable companies to claim the Research and Experimentation Tax Credit (hereinafter “RTC”) utilizing the Alternative Simplified Credit (hereinafter “ASC”) methodology on amended tax returns. This represents a true paradigm shift from the previously issued set of treasury regulations which only allowed companies to take the RTC utilizing the ASC on originally filed tax returns.
This paradigm shift was made possible through the bipartisan support on both sides of the aisles in Congress including, but not limited to, Coons (D-DE), Cornyn (R-TX),Grassley (R-IA), Hatch (R-UT) Klobuchar (D-MN) Roberts (R-KS), Schumer (D-NY) and Wyden (D-OR), Brady (R-TX), Camp (R-MI), Gerlach (R-PA), Jenkins (R-KS), Neal (D-MA) and Linda Sanchez (D-CA). In addition, the unbridled support of Mark Mazur, Assistant Secretary of the Treasury (Tax Policy), John Dalrymple, Deputy Commissioner for Services and Enforcement at the Internal Revenue Service as well as David Selig at Treasury was critical in support of this procedural change.
For the complete scope and application of this tax law change, please contact me directly and consult: Peter Scalise
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