Intragroup Transactions Under the Proposed Research Credit Regs

Intragroup Transactions Under the Proposed Research

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On December 12, 2013 the IRS issues proposed regulations regarding the computation of the research credit for a controlled goup that includes one or more foreign corporations that derive foreign-source gross receipts. The proposed regulations address whether a controlled group can exclude from its credit calculation gross receipts resulting from an intragroup transaction that involves the same property or services that a foreign group member ultimately sells to a person outside the group. 

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