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R&D Tax Credit: Managing Section 174 in Uncertain Times


This webinar was previously titled " MANAGING SECTION 174 IN UNCERTAIN TIMES"
Cost Free
Presentation Length 1.0 hour

Recorded DateOctober 17, 2023
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

In 2017, the Tax Cuts and Jobs Act (TCJA) was passed and contained many provisions that were immediately effective. However, one of the provisions that received less fanfare, in part due to its delayed effective date, was changed to Section 174. Many had hoped that the changes to Section 174, which were effective beginning in 2022, were going to be at the very least delayed. However, with the tax filing season in full swing, it is increasingly unlikely that a retroactive delayed implementation date will be adopted by Congress. Now, companies (large and small) are faced with drastic changes to how they account for certain expenditures, as well as how they need to accumulate data that was previously largely unnecessary. Join Kevin M. Jacobs and Kathleen King, Managing Directors at Alvarez & Marsal, and Robert Kovacev, Member at Miller & Chevalier, for an essential Virtual Coffee Talk.

Learning Objectives:

  • Determine which expenses are subject to the Section 174 capitalization requirement 

  • Identify what short- term and long-term approaches companies should implement to capture the Section 174 costs 

  • Recognize how companies should prepare for a Section 174 audit 

  • List the current legislative and regulatory outlook for the section 174 capitalization requirement

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As a Corporate Research Field Sales Representative for Wolters Kluwer Tax & Accounting, Kevin has primary responsibility for driving profitable sales growth in an assigned territory that meets or exceeds sales goals. The products sold are CCH tax, accounting, and audit research product lines. Activities include learning and staying informed on the complex and comprehensive Tax & Accounting research product lines; learning and following a comprehensive sales process (including cold calling); updating and managing sales pipeline information for an assigned list of accounts; managing time and resources effectively; representing Wolters Kluwer within the industry and territory; and contributing to the sales planning and forecasting activities.


Prior to joining A&M, Mr. Jacobs was a Senior Technician Reviewer (TCJA) with the IRS Office of Associate Chief Counsel (Corporate) for more than six years, where he advised on tax issues such as corporate re-organizations and corporation-shareholder issues, earning and profits, recovery and allocation of stock basis, liquidations, redemptions, bankruptcies, spin-offs and consolidated returns.

While with the IRS, Mr. Jacobs was the principal Associate Chief Counsel (Corporate) attorney on several regulatory projects including the proposed section 382(h) regulations on built-in gains and losses, the global intangible low-taxed income regulations, and debt-equity regulations. He provided substantial contributions to other guidance projects such as the limitation on interest deductions regulations, and assisted in overseeing the Corporate Division’s response to TCJA, including the coordination with Treasury’s Offices of Tax Legislative Counsel and International Tax Counsel. Previously, Mr. Jacobs spent more than nine years at law and certified public accounting firms (Ropes & Gray LLP, Latham & Watkins LLP, Dewey Ballantine LLP and Arthur Andersen LLP).

Mr. Jacobs earned a bachelor's degree in accounting, a master’s degree in accounting (taxation concentration), a JD (magna cum laude) from the University of Florida and an LLM in taxation from New York University. He is admitted to the District of Columbia and Florida Bars and is a licensed Certified Public Accountant (CPA) in Florida and Colorado. Mr. Jacobs is a member of the American Bar Association and the New York State Bar Association. He is a frequent speaker on numerous corporate transaction tax matters. 


With more than 25 years of experience, Ms. King specializes in assisting clients in claiming, documenting and sustaining tax incentives, including research tax credits, meals and entertainment deduction, energy credits, work opportunity tax credits, and state credits. She has worked with clients across various industries, including aerospace and defense, food products, manufacturing, pharmaceutical products, retail and software.

Ms. King's projects have ranged from targeted consulting engagements designed to address specific issues to large-scale projects utilizing engagement teams working concurrently in multiple locations. She has extensive experience in leading research credit analyses and representing her clients in audits performed by the Internal Revenue Service and state tax authorities at the field and appeals levels. 

Prior to joining A&M, Ms. King served as a national resource for the Research Credit Services teams with Big Four firms.

Ms. King earned a bachelor's degree in mineral land management from the University of Colorado and a master's degree in accounting from American University in Washington, D.C. She is a Certified Public Accountant.

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Robert J. Kovacev's practice focuses on federal tax controversy and tax litigation. He combines extensive first-chair litigation skills with substantive tax knowledge to represent taxpayers in high-profile, high-stakes tax disputes against the Internal Revenue Service (IRS), both at the administrative level and in litigation. These disputes include international tax and transfer pricing issues, the research tax credit, the Section 199 domestic production activities deduction, alternative energy tax credits, and the economic substance doctrines. Mr. Kovacev has more than two decades of experience representing clients in Tax Court and in federal district and appellate courts. Recognized by Forbes for having one of the top tax-related Twitter accounts, Mr. Kovacev is a leader in the emerging field of taxation of robotics and artificial intelligence, and he frequently writes and speaks on the topic.

Prior to joining Miller & Chevalier, Mr. Kovacev was a partner at a global law firm. Before entering private practice, he was a senior litigation counsel in the Tax Division of the U.S. Department of Justice (DOJ), where he was lead trial counsel for the IRS in some of the largest and most complex civil tax cases in the nation. In that position, Mr. Kovacev worked closely with the IRS's Large Business & International (LB&I) Division and top management of the Tax Division to shape litigation strategy on high-priority tax enforcement issues. These cases involved cross-border transactions, Section 482 disputes, Section 199 deductions, research credits, foreign tax credits, corporate reorganizations and acquisitions, and IP valuations, with claimed tax benefits ranging from $10 million to more than $1 billion.

About Our Presenter

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Wolters Kluwer Tax & Accounting is a leading provider of software solutions and local expertise that helps tax, accounting, and audit professionals research and navigate complex regulations, comply with legislation, manage their businesses and advise clients with speed, accuracy, and efficiency – so they maximize the impact they create for their clients. Our focus is giving tax and accounting professionals the ability to grow, manage and protect their business and their clients’ businesses in a fast-moving and ever-changing world. It means that firms can stay ahead of the pack, take advantage of new technologies, transform, and capitalize on new opportunities.

Wolters Kluwer Tax & Accounting is part of Wolters Kluwer (WKL), a global leader in professional information, software solutions, and services for the healthcare; tax and accounting; governance, risk and compliance; and legal and regulatory sectors. We help our customers make critical decisions every day by providing expert solutions that combine deep domain knowledge with advanced technology and services.