Incentive Insider

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Incentive Insider
California and the Substantially All test

California and the Substantially All test

FTB and OTA strike again

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Holland King
Dec 18, 2024
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Incentive Insider
Incentive Insider
California and the Substantially All test
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The California Office of Tax Appeals issued another R&D decision. While the taxpayer was an architectural firm, the opinion gives warnings to all taxpayers wanting to claim the CA R&D credit. California puts its spin on the “substantially all” test and the documentation standard.

Photo by Lance Anderson on Unsplash.

Background

The appeal was brought by fou…

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