A recent opinion by the California Office of Tax Appeals (OTA) ruling against an apparel industry taxpayer demonstrates a continuing trend by federal and state taxing authorities to focus on a taxpayer’s ability to substantiate adherence to meeting each element of the four-part test under section 41—most notably the process of experimentation requirement. In addition, the ruling indicates increasing scrutiny regarding a project’s activities having been undertaken for a permitted purpose.
Taxpayers rejoice! A recent case decision signals good news for the R&D legal landscape—Audio Technica U.S., Inc. v. U.S. In this case, the taxpayer was a manufacturer of high-quality audio and microphone equipment. After being denied its claimed research credit during audit, the taxpayer sought to litigate the issue through the Northern District of Ohio in June of 2019 in an 8-person jury trial.
On April 9, 2020 the Treasury Department and the Internal Revenue Service announced another round of relief provisions in response to the COVID-19 pandemic. This new wave of relief measures is intended to provide further benefits to taxpayers in addition to the previous measures already implemented.
Many of you have probably have heard of “cross-training.” The term usually conjures up images of gym clothes-clad men and women sweating through workouts.
With this exercise approach, a person alternates their workout activities. The intent is to affect a more comprehensive range of muscles and to increase both cardio tolerance and muscle growth, with less chance of injury.
“It's not the size of the dog in the fight, it's the size of the fight in the dog.”
Mark Twain, the great American writer, humorist, entrepreneur, publisher, and lecturer, is credited with authoring this wise quote. The quote speaks to tenacity, perseverance, and resilience, and how these qualities are not a matter of size, but rather attitude.
Back in the 80s, many a kid – and probably adults, too – dreamed of having their own Knight Industries Two Thousand - or KITT. KITT was the car co-star in the hit TV series, Knight Rider. The souped-up, technologically tricked-out Trans Am and his driver, Michael Knight, helped slam the brakes on crime for a private public-justice foundation.
Even if you weren’t around to experience it on the big screen, most of you are probably familiar with the 1984 hit movie Terminator that immortalized the promise, “I’ll be back.” The sci-fi flick depicts Arnold Schwarzenegger as a deadly cyborg sent back in time to eliminate a woman whose yet-to-be-conceived son will lead the charge to kill the robot’s nefarious creators.
Cyborgs, as portrayed in movies, are virtually computerized versions of walking, talking humans. Right now, they are still a product of the future – mostly. Digital therapeutics are not. Digital therapeutics are computerized variations of manual health therapies.
They watched the Lone Ranger ride his white horse across the world’s first televisions and ‘cruised the circuit’ in their ‘woodies.’ They swiveled their hips with Elvis Presley, drove to the drive-in to make out, developed the ‘burbs, and received the first polio vaccinations. They witnessed the fall of segregation, the rise of mega-corporations, and the take-off of transglobal passenger flights. Through all of this, they were ‘swell’ and ‘groovy,’ and wore ‘boss threads.’
Smart inhalers. Artificial irises. Heart failure sensor implants and wireless brain sensors. Surgery robotics, artificial organs, papyrus covered coronary stints – this is just a sampling of the most recent and advanced medical devices in use or soon to be.
These and other medical devices possess the power to detect distress, monitor conditions, and improve patients’ lives and ability to manage their health. They allow doctors and caregivers to diagnose and address ailments with greater accuracy and speed. Never before has technology been so grafted to healthcare.
When the first “motorized carriages” rolled onto the road, safety and luxury features were not included - the motorized vehicle itself was the luxury...and safety?
But my, how far we’ve come. We’ve gone from no side or rearview mirrors to backup cameras and blind-spot alerts, from no seat belts to three-point harnesses and airbags, no windows to shatterproof glass. We now ride safely with anti-lock and automatic brakes, crash impact zones, padded dashboards, lane departure warnings, etc.
