From Ravi’s Perspective
Ravikumar established a company in Sunnyvale with a 100% subsidiary in India. He kept using India to his advantage by involving Indian engineers in Research and Development. Although Ravi’s parent firm owns the intellectual property, it incurs some of the costs in the USA and employs India as a development center.
The issue then becomes how these expenses are evaluated from both a deductibility and an R&D Credit perspective. R&D costs were previously kept for book purposes but could be eliminated for tax purposes. However, the TCJA brought about modifications, requiring that R&D expenses be capitalized and written down over time for tax reasons.
The issue then becomes how these expenses are evaluated from both a deductibility and an R&D Credit perspective. R&D costs were previously kept for book purposes but could be eliminated for tax purposes. However, the TCJA brought about modifications, requiring that R&D expenses be capitalized and written down over time for tax reasons.
From Satish’s Perspective:
A fully owned subsidiary of his Indian semiconductor product company is located in the US. The US entity hired certain contractors and personnel to work on IP development, while the Indian entity retains ownership of the IP.
The issue then becomes how these expenses are evaluated from both a deductibility and an R&D Credit perspective. R&D costs were previously kept for book purposes but could be eliminated for tax purposes. However, the TCJA brought about modifications, requiring that R&D expenses be capitalized and written down over time for tax reasons.
The issue then becomes how these expenses are evaluated from both a deductibility and an R&D Credit perspective. R&D costs were previously kept for book purposes but could be eliminated for tax purposes. However, the TCJA brought about modifications, requiring that R&D expenses be capitalized and written down over time for tax reasons.
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