Treasury Discovers Problems with New Research Tax Credit Regulations

Posted: 7 Mar 2001


In a follow-up to his special report, "Qualified Research and the Short, Fast Life of the 'Discovery Test'," Tax Notes, Oct. 16, 2000, p. 403, Click looks at the "final" research and experimentation tax credit regulations, and the Treasury Department's suspension of the regulations on January 31, 2001. The regulations contain many new sections that were not part of the 1998 proposed regulations and were not subject to public comment. In addition, the IRS continues its reliance on the "discovery test" as part of the definition of "qualified research," which may cause congressional reaction. The article discusses the new provisions, Treasury's decision to reopen the comment period, and what practitioners can expect in the coming months.

Suggested Citation

Click, David L., Treasury Discovers Problems with New Research Tax Credit Regulations. Available at SSRN:

David L. Click (Contact Author)


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