More about Michael DePrima

  • 303-439-6093


Blog Posts by Michael DePrima:

  • Tech companies should plan now for Section 174 capitalization for tax year 2023 and beyond

    Will it get fixed? This time last year there was optimism that a 2022 year-end fix would be passed by Congress and Section 174 research capitalization would be deferred or eliminated altogether. Instead, Congress failed to act and tax year 2022 proved to be one of the most challenging for taxpayers subject to Section 174. […]

    Read More

  • R&D payroll tax credit increases for 2023

    By Ginny Veit Companies performing research and development (R&D) activities in 2023 can take advantage of a supercharged R&D tax credit against their payroll taxes. The payroll credit can be a hugely valuable cash flow tool for early stage tech companies that should be part of your year-end planning discussions. The payroll tax election under […]

    Read More

  • IRS releases new Section 174 research capitalization guidance

    IRS recently announced that proposed regulations are forthcoming under Section 174 while also providing interim guidance. Check out our latest article to see what this development means for tech companies: IRS to Propose Section 174 Regulations, Interim Guidance Issued : 2023 : Articles : Resources : CLA (CliftonLarsonAllen) (claconnect.com).

    Read More

  • Uncertainty in the new world of section 174 capitalization

    Check out our latest update on research expense capitalization under Internal Revenue Code section 174. Topics include the legislative state of play, confusion over the technical application of section 174, and whether companies should extend their 2022 tax returns. https://www.claconnect.com/en/resources/articles/2023/section-174-capitalization-uncertainty-answers-to-top-faqs

    Read More

  • IRS Issues §174 Capitalization Guidance

    On December 12, the IRS issued Revenue Procedure 2023-8 setting forth guidance for taxpayers making accounting method changes under the new §174 capitalization rules that went into effect on January 1, 2022. The guidance comes at a time when taxpayers and practitioners are still hopeful that the capitalization requirement will be deferred or eliminated by […]

    Read More

  • Section 280G and Parachute Payments: The Distraction In Your M&A Deal

    Tech companies and their executives are often subject to IRC Section 280G when undergoing a change in control. Check out our recent article providing a basic framework for understanding how Section 280G applies in a transaction and how it can be addressed: Section 280G and Parachute Payments: The Distraction In Your M&A Deal : 2022 […]

    Read More

  • While we wait for a Section 174 fix, software companies may feel the largest impacts

    Taxpayers and practitioners had hoped that a “fix” under Section 174 would have been addressed by Congress already. With the first quarter of 2022 behind us, however, we still have no legislation in place that would defer or eliminate the amortization requirement that went into effect for tax years beginning after December 31, 2021. This […]

    Read More

  • Uncertainty Continues for Section 174 Expensing

    With the Build Back Better Act (BBBA) being all but dead in the Senate after Joe Manchin’s unexpected rejection of the bill, concerns remain high regarding the future of Section 174 of the Internal Revenue Code. Section 174 allows taxpayers to currently deduct research and experimental (R&E) expenditures, rather than having to capitalize and amortize […]

    Read More