Whose Qualifying Research Expense Is It, Anyway?

Whose Qualifying Research Expense Is It, Anyway?


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Across all industries, U.S. controlled group members often exchange employees' time and expertise with other controlled group members (both domestic and foreign). Unique transactions may take place among these entities, specifically with respect to the performance of and payment for research activitites. This article considers some challenging questions these transactions may pose, with a focus on which member of the controlled group is permitted to claim amounts as qualifying research expenses (QREs) for the research credit. 

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