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Credit for Increasing Research Activities; Correction

---
identifier: "/us/fr/05-15827"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Credit for Increasing Research Activities; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "05-15827"
section_name: "Credit for Increasing Research Activities; Correction"
positive_law: false
currency: "2005-08-12"
last_updated: "2005-08-12"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "05-15827"
document_type: "rule"
publication_date: "2005-08-12"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BE17"
fr_citation: "70 FR 47108"
fr_volume: 70
docket_ids:
  - "TD 9205"
effective_date: "2005-05-24"
fr_action: "Correcting amendment."
---

#  [Corrected]

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**SUMMARY:**

This document corrects temporary regulations (TD 9205) that were published in the *Federal Register* on Tuesday, May 24, 2005 (70 FR 29596). The document contains temporary regulations relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations or a group of trades or businesses under common control.

**DATES:**

This correction is effective on May 24, 2005.

**FOR FURTHER INFORMATION CONTACT:**

Nicole R. Cimino, (202) 622-3120 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The temporary regulations (TD 9205) that is the subject of this correction are under section 41(f).

**Need for Correction**

As published, the temporary regulations (TD 9205) contain errors that may prove to be misleading and are in need of clarification.

**List of Subjects in 26 CFR Part 1**

Income Tax, Reporting and recordkeeping requirements.

**26 CFR Part 1**

**Correction of Publication**

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:

**PART 1—INCOME TAXES**

*Paragraph 1.* The authority citation for part 1 continues to read in part as follows:

**Authority:**

26 U.S.C. 7805 * * *

§ 1.41-6T

1. Section 1.41-6T(e) *Example 2* (i), the first line in the table is revised to read as follows:

|  | D | E | F | G | Group Aggregate |
| --- | --- | --- | --- | --- | --- |
| Credit Year QREs | $580x | $10x | $70x | $15x | $675x |
|  |  |  |  |  |  |
| *         *         *         *         *         *         * |  |  |  |  |  |

**26 CFR Part 1**

2. Section 1.41-6T(e) *Example 2* (i), second line in the table is revised to read as follows:

|  | D | E | F | G | Group Aggregate |
| --- | --- | --- | --- | --- | --- |
|  |  |  |  |  |  |
| *         *         *         *         *         *         * |  |  |  |  |  |
|  | $500x | $25x | $100x | $25x | $650x |

**26 CFR Part 1**

3. Section 1.41-6T(e) *Example 2* (ii)(B)( *1* ), the first sentence is revised to read as follows: “The group's base amount equals the greater of: the group's fixed-base percentage (3.10 percent) multiplied by the group's aggregate average annual gross receipts for the 4 taxable years preceding the credit year ($17,000x), or the group's minimum base amount ($337.50x).”

**26 CFR Part 1**

4. Section 1.41-6T(e) *Example 2* (iii), the eighth sentence is revised to read as follows: “Because the group credit of $29.76x is greater than the sum of the stand-alone entity credits of all the members of the group ($21.67x), each member of the group is allocated an amount of the group credit equal to that member's stand-alone equity credit.”

**26 CFR Part 1**

5. Section 1.41-6T(e) *Example 2* (iii), the ninth sentence is revised to read as follows: “The excess of the group credit over the sum of the members' stand alone entity credits ($8.09x) is allocated among  the members of the group based on the ratio that each member's QREs bear to the sum of the QREs of all the members of the group.”

**26 CFR Part 1**

6. Section 1.41-6T(e) *Example 2* (iii), the fourth line in the table is revised to read as follows:

|  | D | E | F | G | Total |
| --- | --- | --- | --- | --- | --- |
|  |  |  |  |  |  |
| *         *         *         *         *         *         * |  |  |  |  |  |
| Excess Group Credit | $8.09x | $8.09x | $8.09x | $8.09x |  |
|  |  |  |  |  |  |
| *         *         *         *         *         *         * |  |  |  |  |  |

**26 CFR Part 1**

7. Section 1.41-6T(e) *Example 3* (ii)(C), the second sentence is revised to read as follows: “The excess of the group credit over the sum of the members' stand-alone entity credits ($10.00x) is allocated among the members of the group based on the ratio that each member's QREs bear to the sum of the QREs of all the members of the group.”

**26 CFR Part 1**

8. Section 1.41-6T(e) *Example 3* (ii)(C), the fourth line in the table is revised to read as follows:

|  | DE | F | G | Total |
| --- | --- | --- | --- | --- |
|  |  |  |  |  |
| *         *         *         *         *         *         * |  |  |  |  |
| Excess Group Credit | $10.00x | $10.00x | $10.00x |  |
|  |  |  |  |  |
| *         *         *         *         *         *         * |  |  |  |  |

**26 CFR Part 1**

9. Section 1.41-6T(e) *Example 3* (iii)(C), the fourth line in the table is revised to read as follows:

|  | D | E | Total |
| --- | --- | --- | --- |
|  |  |  |  |
| *         *         *         *         *         *         * |  |  |  |
| Excess Group Credit | $6.83x | $6.83x |  |
|  |  |  |  |
| *         *         *         *         *         *         * |  |  |  |

**26 CFR Part 1**

10. Section 1.41-6T(e) *Example 5* (iii), the first sentence is revised to read as follows: “Under paragraph (c)(2) of this section, the stand-alone entity credit for each member of the group must be computed using the method that results in the greater stand-alone entity credit for that member.”

**26 CFR Part 1**

11. Section 1.41-6T(j), the second sentence is revised to read as follows: “Generally, a taxpayer may use any reasonable method of computing and allocating the credit for taxable years ending before May 24, 2005.”

Guy Traynor,

Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedures and Administration).