Daily Tax Update - April 2, 2015: Treasury, IRS Release Research Credit Regulations

Treasury, IRS Release Research Credit Regulations:  The IRS has issued final and temporary regulations (T.D. 9717) regarding the allocation of the section 41 research credit to businesses under common control.  The regulations reflect changes made to section 41 by section 301(c) of the American Taxpayer Relief Act of 2012, P.L. 112-240, and generally reflect interim guidance previously provided in Notice 2013-20.  The regulations also address the allocation of the railroad track maintenance credit and the election for a reduced research credit.  

IRS Guidance Provides New Safe Harbor Employee Plan Correction Methods:  Today, the IRS issued Revenue Procedure 2015-28, which modifies Revenue Procedure 2013-12.  The modifications include new safe harbor Employee Plans Compliance Resolution System (EPCRS) correction methods relating to automatic contribution features (including automatic enrollment and automatic escalation of elective deferrals) in plans described in sections 401(k) and 403(b).  The guidance also provides special safe harbor correction methods established for plans (including those with automatic contribution features) that have failures that are of limited duration involving elective deferrals.