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Success Stories

Fortune 500 manufacturer benefits from depth of knowledge

Recent regulatory changes prompted this client to seek reliable R&D credit expertise. Our experienced team developed a methodology for identifying and calculating pilot plant costs as part of the R&D study.

"We consider ourselves a highly innovative company. It's so satisfying to have partnered with an equally innovative provider."

The Background

This Fortune 500 manufacturer sought to introduce a new line of beverages, investing heavily in developing two new manufacturing plants. The taxpayer had been calculating its R&D credits internally for many years. However, due to the promulgation of the pilot plant regulations and their lack of expertise with this specific issue, the taxpayer sought to outsource this portion of their R&D study.

TCC Approach

Technical Expertise:

  • New guidelines enabled taxpayers, under certain limited circumstances, to treat the costs of a pilot plant, or some subset thereof, as supply QREs. Since these rules were relatively new at the time, TCC developed a substantiation methodology that helped the company apply the new regulations to their project facts.

Audit Focused Deliverables:

  • With an IRS controversy expert embedded from the beginning of the study, we worked with the taxpayer to identify potential exam challenges and prepare an audit-ready deliverable. TCC completed the analysis and the taxpayer filed refund claims which the IRS audited. Ultimately, the refund claims were accepted as filed.

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