Paradigm Partners Newsletter

November 2012

What Some People Are Saying About Us

"We are planning to pursue this each year, as long as we have products that qualify for the act...I would strongly recommend it. I have already recommended [Paradigm] to numerous business owners."

 

Jerry Lawson
CEO
WW Wood, Inc.

Click Here to listen to the full interview.

 

USAbout 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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In This Issue:
 

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U.S. v. Davenport: Defining a gray area in software R&D credits
 by 
Lyndsie Lowry, Attorney at Law and Saqib Dhanani, Attorney at Law

 

Congress enacted the Credit for Increasing Research Activities (the "R&D credit") in 1981, and since that time, the law has undergone several major revisions. However, the law has not been the only thing to change. Since its original enactment, technology has advanced and evolved in ways to which the law has had difficulty adapting. With the rapid expansion of software development since the early 1990s, the R&D regulations have struggled to remain current in the face of changing vocabulary and activities, creating an expansive gray area for software claims.

 

In U.S. v. Davenport, the U.S. District Court for the Northern District of Texas examined software expenditures claimed under the R&D credit. The credit was claimed by members of the Davenport family, owners of the Burly Corporation, which manufactures metal roofing and standalone metal buildings through its subsidiary, Mueller Supply Company. The Davenports claimed the R&D credit based on software installation and configuration at the Mueller facility. Ultimately, the court granted the IRS' summary judgment motion, holding the Davenports' activities were not qualified research under the Code.

 

Davenport is significant because it sheds light on the circumstances under which the IRS will reject software-based R&D credits.

Click Here to Read the Full 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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Fiscal Cliff 2012 and the R&D Tax Credit:

Loss of R&D Tax Credit May Lead To Layoffs
by
Bart Shuldman
CEO, Transact Technologies

 

So how would the expiration of the R&D tax credit impact the U.S. economy and much needed job growth?

 

Investment in research and development is a significant driver of technical progress and economic growth. The goal of the R&D tax credit is to encourage R&D investment by both domestic and foreign corporations in the United States. The effect of not extending the R&D tax credit could have a disastrous impact if these firms go to other countries that actually have better tax advantages that encourage R&D spending.

 

A July 2012 report by the ITIF (The Information Technology & Innovation Foundation) concluded the U.S. has fallen behind other nations regarding R&D tax credits. Countries such as Brazil, Canada, China, France and India have implemented tax credit programs that are more generous than the U.S. Even countries with economic budget challenges have significantly expanded their R&D tax incentives.

 

The study determined that the U.S. now ranks 27th out of 42 countries in R&D tax benefits, down from 23rd just five years ago. If the R&D tax credit is not extended, the U.S. could lose out on the capital investment, economic growth and high-wage R&D jobs these investments bring. I cannot imagine the economic impact and the loss of technology leadership in the U.S. if the existing tax credit program expired. 

 

 

 

Contact Karim Solanji at 281-558-7100 or KSolanji@ParadigmLP.com to learn more about an 

R&D Tax Credit study.



 

Contact Us
 
Karim Solanji
Director
Paradigm Partners
281-558-7100

www.ParadigmLP.com