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The Research & Experimentation Tax Credit or R&D Tax Credit is a general business tax credit under Internal Revenue Code section 41 for companies that incur research and development (R&D) costs in the United States. The R&D Tax Credit was originally introduced in the Economic Recovery Tax Act of 1981 sponsored by U.S. Representative Jack Kemp and U.S. Senator William Roth.〔''Encyclopedia of Taxation and Tax Policy'', By Joseph J. Cordes, Robert D. Ebel, Jane Gravelle, Urban Institute, pages 330-332〕 Since the credit's original expiration date of December 31, 1985, the credit has expired eight times and has been extended fifteen times. The current extension expires on December 31, 2014.〔http://www.irs.gov/pub/irs-pdf/f6765.pdf〕 However, it may be renewed again for 2015, as it has been 16 times since 1981, usually retroactively to when the credit last expired.〔(''Temporary tax breaks _ which ones affect you?'', Yahoo/AP )〕 ==Qualified research, history and definitions== With widespread concern that U.S. economic performance had fallen well below its potential, Congress passed 'The Economic Recovery Tax Act' (ERTA) of 1981. The ERTA was intended to act as an economic stimulus that would encourage investment within the United States. Congress perceived that research spending declines had adversely affected the Country's economic growth, productivity gains, and competitiveness within the global marketplace (defined by the fall of the American automaker). Included within the ERTA was a provision called the 'Credit for Increasing Research Activities' (the Credit). The Credit was tailored to reverse the decline in U.S. research spending by providing an incentive that was premised on benefiting increases in (as opposed to total) year over year research spending. Originally embodied within House Report No. 97-201 (H.R. 4242) and then later codified by The Tax Reform Act of 1986, 'Qualified Research' generally constitutes private sector or commercially driven development effort intended to yield innovation within a scientific or technological field. However, administrative difficulties coupled with divergent interpretations by the IRS and Taxpayers have led to a series of revisions to the Code Section and related Treasury Regulations. In practice, 'Qualified Research' is often reduced to a "Four Part Test" to provide a frame of reference. However, this can be misleading due to the number of requirements or elements within each "Test" and the extensive Regulations that were provided to supplement some parts of Section 41 with examples. This convention belies the need for fact intensive evaluations and documentation of taxpayer research efforts over a period of time on the business component level (see below). This evaluation can be further complicated by a large body of case law and the need to reconcile research activities with allowable expenditures. Not coincidentally, while the Credit celebrated its 30th year of existence in 2011, significant rulings have been issued in the preceding few years (with more in process) as technology and methods change which is a by-product of what the Credit, ironically, was designed to promote. Perhaps in light of this and given the shift towards compliance based tax reporting over the last decade, taxpayers have increasingly relied upon niche tax professionals to assess research activities/projects on their behalf. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Research & Experimentation Tax Credit」の詳細全文を読む スポンサード リンク
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