Detail Internal-Use Software and The Research Credit   Oleh:  Knight, Ray A. ; Knight, Lee G. ; Nix, Wayne E. Jenis: Article from Bulletin/Magazine Dalam koleksi: Journal of Accountancy vol. 188 no. 6 (1999), page 79. Topik: software; software; research credit Ketersediaan Perpustakaan Pusat (Semanggi) Nomor Panggil: JJ85.9 Non-tandon: 1 (dapat dipinjam: 0) Tandon: tidak ada     Lihat Detail Induk Isi artikel Computers often need software tailored to a company’s needs, but businesses that develop internal - use programs have struggled for years with scant corporate - tax guidance on how to qualify such software for the IRC section 41 research tax credit. A financial manager whose employer plans to develop software in - house may be able to structure such a project more advantageously after looking at the rules and how the courts interpret them. Although the code does not define internal - use software, the legislative history describes it as software that "supports general and administrative functions (such as payroll, bookkeeping or personnel management) or provides noncomputer services (such as accounting, consulting or banking services)". Enacted as part of the Economic Recovery Tax Act of 1981, the original credit made no direct provision for internal - use software. The accompanying House of Representatives report, however, indicated the credit applied to only new or significantly improved software. Congress created an opportunity for internal - use software in the Tax Reform Act of 19 86 (TRA’86), but ended up leaving it a gray area. The amended credit expressly excluded internal - use software from the definition of qualified research, but included it in two statutory exceptions and in exceptions the regulations would provide. In 1997 - more than 10 years later - the Treasury Department finally released proposed regulations. Treasury didn’t go out on a limb, and the proposals do little more than echo the TRA ’86 conference report. Most companies already apply these requirements, so the proposed regulations still don’t resolve questions about the eligibility of internal - use software for the research credit. Case law on the treatment of internal -use software under section 41 is limit ed. However, two recent cases - Norwest v. Commissioner [110 T. C. 454 (1998)] and United Stationers, Inc. v. U. S. [982 F.Supp. 1279 (N. D. Ill. 1997), on appeal (7 th Cir., Dec. 23, 1997)] - provide insight into how the courts qualify internal - use software for the research credit, based on statutory and regulatory requirements. These cases (particularly Norwest, because of its extensive analysis), administrative rulings and the credit’s legislative history give CPA s some insight into how these rules are applied, which is critical given the explosive growth of software development today. Opini Anda Klik untuk menuliskan opini Anda tentang koleksi ini! Kembali

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