Shea Malone

Shea Malone
Shea is a Director in the Audit & Quality Assurance Department. She has valuable knowledge in federal tax planning and research credit services. Her background in law and tax controversy earned her opportunities to defend her clients' research credit studies before the IRS.
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Recent Posts

Recent California Legislation Will Have Taxpayers Considering New Tax Planning Strategies

Written by Shea Malone. Updated Jul 12, 2024.

New budget legislation, SB 167, passed by the California Legislature on June 13th and signed into law by the governor on June 27, 2024 will have significant impacts on taxpayers by suspending net operating loss (NOL) deductions and limiting the utilization of credits from 2024 through 2026.

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Hope on the Horizon: Will Amortization of R&E Expenses Stand?

Written by Shea Malone. Updated Mar 9, 2022.

There’s still hope that the Tax Cuts and Jobs Act’s (TCJA) changes to Section 174, requiring amortization for research and experimental (R&E) expenses, could be delayed or repealed. Under the TCJA, as of January 1, 2022, domestic R&E expenditures are required to be amortized over 5 years and foreign R&E expenditures over 15 years. Prior to January 1, 2022 taxpayers had been able to write-off 100% of R&E costs.

The new definition of R&E expenditures under Section 174 also includes software development costs. Previously, under Revenue Procedure 2000-50, taxpayers had the option to immediately expense or amortize software development costs over a period of 36 or 60 months. With the TCJA change, these options are no longer available. Domestic software development costs must be amortized over 5 years and foreign software development must be amortized over 15 years.

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