Gain a better understanding of the considerations and requirements of the research tax credit.
On October 15, 2021, the IRS issued Field Attorney Advice (FAA) 20214101F, which attempts to require specific and extensive documentation for any R&D credit refund claim that differs substantially from historic statutory and regulatory requirements. Subsequent to the issuance of the FAA, the IRS issued Interim Guidance and FAQs to provide IRS Examining Agents with procedural guidance for applying FAA 20214101F in an examination of a taxpayer's refund claim under Section 41.
Due to these significant changes to the statutory and regulatory requirements for research credit refund claims, taxpayers must reevaluate their historic filing processes and positions to ensure they comply with the new heightened requirements. This course will help taxpayers understand the differences between the statutory requirements and those now imposed under FAA 20214101F and the requirements needed to properly substantiate a research credit refund claim under the new guidance. As the new requirements took effect on January 10, 2022, and with a limited window period to perfect deficient claims available through January 9, 2023, this information is critical for taxpayers that have filed or are considering filing a research credit refund claim to ensure such claims are fully substantiated under the new requirements.
Agenda
Faculty
Michael Resnick
Eversheds Sutherland (US)
- Associate at Eversheds Sutherland
- Focus on federal taxation matters, including tax accounting methods and compliance, planning and controversy issues; regularly counsel clients on the proper tax treatment of transaction costs associated with tangible property, intangible property, and corporate transaction costs; also counsels on tax restructurings and the regulation and taxation of tax-exempt organizations
- Regularly represents clients before the Internal Revenue Service (IRS), including representation at the IRS National Office with private letter rulings and technical advice; also represents a number of clients in controversy matters before the Examination and Appeals divisions, including matters involving Fast Track Appeals and the Compliance Audit Program
- Speaks throughout the country at ABA Section of Tax meetings, both local chapter and national TEI events, and FBA meetings, as well as Eversheds Sutherland-sponsored CLE/CPE events, on the latest development in tax accounting and federal taxation
- Nolan Fellow, Section of Taxation, ABA (2021-2022)
- Tax Lawyers See Roadmap in Tax Accounting Decision (May 3, 2002) Tax Notes; A Timely Update: The IRS and Treasury release Rev. Proc. 2022-14 Updating List of Automatic Accounting Method Changes (February 4, 2022), Eversheds-Sutherland.com; While April Showers Can Bring May Flowers, New Legislation Certainly Brings Tax Filing Challenges (March 29, 2021), Bloomberg Tax
- ABA Section of Tax, Tax Accounting committee, FBA Section of Tax, DC Bar and Virginia State Bar.
- LL.M. degree in taxation, Georgetown University Law Center; J.D. degree, Temple University James E. Beasley School of Law; B.A. degree, University of Virginia
- Can be contacted at [email protected] or 202-383-0965
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