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About Us
Paradigm Partners is an international consulting firm specializing in complex federal and state tax and funding incentives, for both public and private entities, across a host of industries. Paradigm Partners has distinguished itself among its peers by adopting a low cost, high return service model that employs a tailored two-phase approach. The Company's business development and professional teams work hand in hand to provide accurate analyses, establish effective client dialogues, and guarantee rapid turnaround times.
Paradigm's staff is comprised of a highly selective pool of intellectual property and tax attorneys, engineers, PhDs, and CPAs. Company personnel utilize not only years of industry expertise, but their numerous academic achievements from distinguished institutions across the globe.
The Company's core consulting portfolio includes Global R&D Tax Credits Analyses, Hiring and Location- Based Incentives, Unemployment Claims Management, IC-DISC, Domestic Production Deduction, Grant and Non-dilutive Funding Advisory, Cost Segregation Studies, Tax Controversy, Patent and Audit Defense Services.
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Gross Receipts Include More Than Just Sales
Lee Carver, Attorney at Law, Thanh Ngo, Attorney at Law, and Saqib Dhanani, Attorney at Law
When claiming the federal Research and Development tax credit promulgated under Section 41 of the Internal Revenue Code (IRC), taxpayers are sometimes required to determine their average annual gross receipts to compute the credit. The average annual gross receipts for a tax year consist of the mean amount of gross receipts generated by the taxpayer during the prior four tax years. The Internal Revenue Service (IRS) has long held that "gross receipts" include all revenues generated by a company except for those listed in 26 CFR §1.41-3(c)(2), such as long term capital gains, returns or allowances, and repayments of loans or similar instruments. That is to say, the IRS embraces a broad, inclusive definition of gross receipts; unless an exclusion exists in §1.41-3(c)(2), all other sources of income should be included in a tax payer's gross receipts. But over the years, some taxpayers have argued that "gross receipts", for the purpose of the R&D tax credit, is limited to the difference between gross receipts from sales and returns and/or allowances, typically found on lines 1(a) and 1(b) of Forms 1120, 1120S, and 1065. On September 25, 2012, however, a U.S. Tax Court ruling definitively laid this dispute to rest and sided with the IRS. Contact Karim Solanji at 281-558-7100 or KSolanji@ParadigmLP.com to learn more about an R&D Tax Credit study. |
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Tax Extenders Renewal Gains Momentum
by
Monica McGuire
The renewal of temporary tax provisions, such as the R&D tax credit, has come to the forefront of congressional debates. Tremendous support from various lawmakers to renew tax extenders has pushed the issue into this prime position. Legislation surrounding several tax extenders will be discussed during this year's Lame Duck session.
"The temporary tax provisions that typically expire every year or two, e.g. R&D tax credit, got a boost of bipartisan, bicameral energy this week with Senate Majority Leader Harry Reid (D-NV) attempting to advance on the Senate floor tax extenders bill S. 3521 and House Ways and Means Committee chairman Dave Camp (R-MI) echoing support for moving some of these tax provisions during the upcoming Lame Duck session. Congressional leaders and tax-writing committee leaders were not the only lawmakers this week calling for action to renew tax extenders."
Click Here to Read the Article
Contact Karim Solanji at 281-558-7100 or KSolanji@ParadigmLP.com to learn more about an R&D Tax Credit study.
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