R&E tax credits

Plan to make permanent the current tax credits for research and experimentation expenditures is under consideration by the Senate Finance Committee for inclusion in the budget reconciliation package. The House passed a provision making the tax credit permanent on Oct. 5 in its Omnibus Budget Reconciliation bill, HR 3299. The House plan would restructure the tax credit by changing the definition of "spending base" by indexing it to individual company sales; the Finance Committee is considering a similar approach. The House also agreed to provide a permanent rule under which companies would allocate 64% of expenses for R&E conducted outside the U.S. to foreign source income.