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2022 72nd Midyear Conference

M03 - Significant Legal Developments for Crediting, Deducting, and Amending Research and Experimental Expenditures: What Should I Know and How Should I Respond?

Mar 21, 2022 9:45am ‐ Mar 21, 2022 10:45am


Aggressive IRS enforcement of research credits and recent legislation impacting the treatment of section 174 research and experimental expenses have resulted in significant legal and administrative changes that may materially impact future return positions. In response, TEI has assembled a team of leading experts to break down the developments and explain their practical impacts. Our panelists will analyze a variety of topics, such as the new, extremely rigorous reporting standards for research credit refund claims, the impact of Little Sandy Coal on determining what expenses qualify for the credit, the new 5-year amortization requirement for section 174 R&E expenses, IRS practice developments and their impacts on how taxpayers claim, document and defend section 41 credits, and technological advances companies should consider to support their research credit studies.

At the conclusion of this course, participants should:

  • Understand the practical impacts of the Little Sandy Coal case on determining what expenses qualify for R&E credits;
  • Be aware of and better able to comply with new specificity requirements for R&E claims;
  • Understand law changes impacting the deductibility of section 174 R&E expenses and how such changes may impact future tax returns;
  • Be better prepared for IRS examinations of research credits;
  • Be aware and able to evaluate the usefulness of technological advances that may improve the collection of data in research credit studies


  • Mr. Brian P. Kaufman, TEI Vice President, Region IV - Vice President, Tax Audits & Tax Counsel, Capital One Financial Corporation



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