Group50 Consulting

JIM, GREAT SUMMARY AND INSIGHT. I WILL BE IN TOUCH...

2012-04-17T22:05:17.763-07:00

JIM, GREAT SUMMARY AND INSIGHT. I WILL BE IN TOUCH THIS WEEK,
PHIL BOGNER

I have always known that culture was a big culprit...

2012-03-25T09:49:39.274-07:00

I have always known that culture was a big culprit in the failure of acquisitions to meet their potential. What are some of the techniques readers have used to work on this issue?

I think Mr. Ragow was trying to cater to a broad, ...

2011-07-15T08:33:23.574-07:00

I think Mr. Ragow was trying to cater to a broad, undefined audience (from tax directors to company owners) and wanted to spur interest rather than debate about the interpretation of various issues. That said and for clarification, the IRS view on the R&D Credit Rules can be found in its Audit Techniques Guide for the R&D Tax Credit, which is not law (but does provide a nice framework for navigating this issue). An auditor is instructed by the ATG that the taxpayer may use whatever documentation is available to substantiate qualification of activities as R&D and the associated costs therewith (emails, meeting notes, and so forth). I think the broader point of the article concerned two fundamental principles - removal of the discovery rule and elimination of the specific, statutory documentation requirements for the Credit - as promulgated in the Final Treasury Regulations in 2003. Other information re: estimates, wage expenditures, direct costs, etc. of which Mr. Ragow has provided a very general overview comes directly from Case Law (reference the taxpayer friendly McFerrin, UCC, and Trinity Cases). As with almost everything in tax, the R&D Credit is largely based on facts and circumstances as presented on a case by case basis. If you (or if you have a client) would like additional information about the R&D Tax Credit, Export Incentives, Negotiated Incentives, or other related tax issues, feel free to visit our website or contact us at 866-244-4170.

This seem to be an over-simplification of the this...

2011-06-05T19:29:37.669-07:00

This seem to be an over-simplification of the this complex area of tax law (for example, the reference to no longer needing concise records to support and R&D tax credit claim).

Being familiar with the Federal R&D credit pro...

2011-05-09T20:59:44.000-07:00

Being familiar with the Federal R&D credit program for some number of years - including increased scrutiny in recent years by the IRS - I must say in candor that I find Mr. Ragow's article overly simplistic. The discussion about what qualifies as R&D, and particularly the record-keeping requirements, strikes me as a a bit thin, to say the least. Sustaining these credits under audit is a fair bit more complicated than indicated, and the implication that a company can support a credit claim with "meeting notes" and such is alarming. I must wonder, of the "over 1,000 studies" by Mr. Ragow and his company, TRCG Advisors, how many have been audited, and how the IRS views their work?

Houston, TX

The writer's representation of qualified R&...

2011-04-25T19:41:24.097-07:00

The writer's representation of qualified R&D activity is startlingly over-broad (e.g., he states that "All of the people (executive, staff and direct labor) that performed in some fashion in the planning, design, prototype development, testing and final approvals – to the degree they worked on R&D efforts – that percentage of their time could be applied to their w-2 wages" - this is is a gross over-simplification of these complex tax rules, and one wonders how the Internal Revenue Service interprets such liberal positioning.

Great post! No company can avoid change if it want...

2010-09-27T15:43:16.963-07:00

Great post! No company can avoid change if it wants to grow and having all the necessary preparations to anticipate issues is just part of effective channel management solutions.

In today's environment, companies I have worke...

2010-09-13T09:12:47.732-07:00

In today's environment, companies I have worked with are challenged by legacy agreements with their customers. I haven't seen any case where there isn't a workaround. Although sometimes painful, most customers understand the need to grow your business and also will be agreeable to an equitable solution. The internet is a classic case where eCommerce provides an additional outlet for companies to expand their customer base, and everyone understands that. Careful planning provides a company the ability to identify its target audience and providing more value add for existing customers.

Great stuff. Too many organizations don't hav...

2010-09-02T15:52:33.141-07:00

Great stuff. Too many organizations don't have the appropriate set of metrics and guiding points that allow employees to clearly see the way forward.