Analysis

Utility's ratemaking treatment of an NOL carryforward

Understand determining whether a utility’s ratemaking treatment of an NOL carryforward complies with the normalization requirements.

Analysis

Definition of Research & Experimentation expenditures under §174 amended

On July 21, 2014, the IRS issued final regulations (TD 9680) (the “Final Regulations”) to amend the definition of R&E expenditures under section 174. Learn more about the changes.

Services

Research & Development and Government Incentives

Many countries offer generous grants, credits, and incentives in areas such as the digital economy, energy efficiency, environment, globalization, innovation, sustainability, and training. Research and development (R&D) incentives provide significant tax benefits at the federal, state, and local level. These benefits are offered for research conducted in the United States, as well as research performed in over 30 other countries that offer research incentives. The R&D credit is one of the most significant of the remaining US domestic tax credits. The Deloitte Research & Development and Government Incentives (R&DGI) tax team is a national team of specialists dedicated to providing broad-based tax incentive services, including research and development, the Domestic Production Activities Deduction, and Government Incentives.

Research and Development Claims Preparation

Identifying eligible R&D activities and preparing effective supporting documentation is often unfamiliar territory for businesses that may not have the personnel or resources needed to complete the paperwork required to file a claim.

Deloitte’s team of professionals assists clients across a variety of industries in increasing benefits and addressing the complex compliance and documentation requirements for the Domestic Production Activities Deduction pursuant to Section 199. This provision allows qualified US taxpayers (corporate, pass-through, or individuals) a special deduction with respect to “qualified production activity income.” This team has developed a standardized approach that includes the use of various analyzer and optimization tools. We analyze the impact of Section 199 and confirm consistency with various international tax regimes to client facts.

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Government Incentives Application Support

To facilitate success from start to finish of a project, companies need assistance with all levels of documentation: specific calculations, provision estimates, technical memoranda, and IRS audit defense, as requested.

To deliver R&DGI services, Deloitte has an Incentives Insight methodology. This is powered by I Smart technology, streamlining and accelerating the gathering and processing of data and information needed to make informed business decisions regarding credits and incentives claims. Many of our projects help clients incorporate cutting-edge data collection and analysis processes into their recurring tax compliance system so a process is established and the client can efficiently pursue ongoing Section 199 benefits.

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Tax Controversy Related to R&D and Government Incentives

R&D claims and Government Incentive applications often receive intense regulatory scrutiny.

Deloitte provides assistance in resolution of any such audits as well as support related to claims and information requests or objections from relevant government bodies. Our team includes many former tax officials who personally participated in the development of R&D credit regulations and rulings. In addition to extensive industry and technical experience, our specialists are supported by an electronic database of work programs, templates, and technical resources that give our professionals a distinct advantage in providing services.

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Business Tax

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Mick Kane

Leader | US R&D and Government Incentives

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