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IRS Guidance Impacting Section 41 R&D Research Credit Claims

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.

100 minutes
Course Exam
Certificate of Completion
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Over 35 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Current Statutory and Regulatory Requirements to File a Research Credit Refund Claim

  • Overview of Section 41 Requirements
  • Current Substantiation Required to Support a Research Credit Refund Claim
  • Policy Supporting Substantiation Requirements

IRS Issuance of FAA 20214101F

  • Discussion of IRS Stated Intent of FAA
  • Compare and Contrast Statutory Substantiation Requirements With FAA Requirements
  • Evaluate Policy Change With FAA

IRS Releases Interim Guidance and FAQs

  • Evaluate Clarifications Provided in Interim Guidance
  • Evaluate Clarifications Provided in FAQs
  • Discuss Practical Considerations of Interim Guidance and FAQs

Implications of FAA, Interim Guidance, and FAQs

  • Discuss Administrative Concerns With FAA
  • Analyze Impact of Heightened Substantiation Requirements
  • Looking Ahead: Discuss Potential Issues With Implementation and Examination
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Why Lorman?

Over 35 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Maine, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on August 3, 2022.

Call 1-866-352-9540 for further credit information.

  • AK CLE 1.5
     
  • Alaska attorneys may receive 1.5 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
     
  • AL CLE 1.7
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.7 hours credit.
     
  • AR CLE 1.5
     
  • This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.5
     
  • The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.5
     
  • Lorman Business Center, LLC. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CT CLE 1.5
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
     
  • GA CLE 1.5
     
  • This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.5 CLE hours.
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • MO CLE 2.0
     
  • This course qualifies for self-study CLE credit in Missouri.
     
  • ND CLE 1.75
     
  • North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.75 hours of CLE credit.
     
  • NH MCLE 1.7
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 99 Minutes.
     
  • NJ CLE 2.0
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 2.0 hours of total CLE credit.
     
  • NM CLE 1.6
     
  • This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.6 hours of credit.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 2.0
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 2.0 hours of CLE credit.
     
  • VT CLE 1.5
     
  • This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
     
  • WI CLE 2.0
     
  • This program qualifies for 2.0 hour(s) of ondemand CLE through the WI Board of Bar Examiners.
     
  • WV MCLE 2.0
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 2.0 MCLE hours.
     

To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • AK CLE 1.5
     
  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • MO CLE 2.0
     
  • NJ CLE 2.0
     
  • NM CLE 1.6
     
  • VT CLE 1.5
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 35 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Michael Resnick

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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Over 35 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 410023
Published 2022
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