Computing the Research Credit for Consolidated Groups.

The article focuses on the rules of the U.S. Internal Revenue Code's Section 41, Chief Council Advice (CCA) 200234063, Technical Advice Memorandum (TAM) 200330001 and 201034017 on research tax credits for consolidated groups. Section 41 treats all members of a group as a single taxpayer in which research credit is calculated for the entire group and then apportioned to the group members. Under the CCA 200234063, all the qualified research expenses of the target corporation are included in the computation of credit.