At MASSIE, we specialize in assisting clients in resolving complex R&D tax credit matters. We defend our own work, and the work done by you, or others. We can step in and represent you in every type of issue with taxing authorities, including auditS or appeals, or even litigation.
As a provider of R&D tax credit services to Fortune 500 companies, MASSIE is experienced in dealing with tax controversy. Whether you are in CAP, under large case exam, facing a MITRE audit, or just received notice of your first exam, MASSIE is your trusted adviser in this area. We can give you peace of mind knowing your issues are being handled by industry experts.
At MASSIE, we start our R&D studies with the end in mind, which is to sustain any R&D tax credits claimed upon audit. Our process of working with SMEs during the study, gathering activity-based information and documentation, and organizing it into our Final Report Navigator helps exams go smoother, leads to better results for you, and less time commitment from your SMEs and your tax department during examination.
With any client facing a new exam, MASSIE will work under power of attorney to represent you from the opening conference through the resolution of any issue. We have guided countless clients through this process, settling most issues quickly and successfully at the examination level. If your tax matter needs to go to appeals, MASSIE has crafted many protests and has experience with appeals and post-appeals mediation across the country. MASSIE uses all settlement tools available to make sure you are satisfied with your results at these levels.
While 99% of R&D tax credit matters can generally be settled without litigation, MASSIE is also experienced in advising clients on the pros and cons of litigation, as we have had clients file suits against the IRS in tax court, and in other federal-level courts. In those cases, our sister company, MASSIE Law Firm LLC, gets involved and will frequently hire co-counsel from Washington, D.C. to assist with the procedural issues of handling the case. MASSIE is still involved in every aspect of the case, available to assist the client with discovery requests, prepping SMEs for deposition, assisting counsel with briefs, and other legal advisory tasks associated with the litigation.
CASE STUDY: Geosyntec Consultants is a nationally recognized environmental engineering firm. When the IRS focused its attention on the R&D tax credit claimed over two tax years, they had a dilemma. Should they hire the CPA firm that did the first-year study, or the CPA firm that did the second-year study? The CFO chose to hire MASSIE to defend the work done by both firms. Upon successful resolution of the issue, MASSIE was hired to perform the next four years of R&D studies. In the next round of IRS exams, MASSIE guided Geosyntec through the examination and appeals processes. Still not satisfied with the audit results, Geosyntec chose to file suit in District Court. Geosyntec Consultants, Inc. v U.S., (S.D. Fla 2013). MASSIE associated Geosyntec with DC counsel at that point and remained a strategic advisor throughout the process, which resulted in a big win for Geosyntec related to fixed-price contracts in the funded R&D area.
Other Controversy Matters have included:
- A St. Louis-based company had an R&D study done by a CPA firm. Upon exam, the CPA firm defended its work, and the examiner disallowed 100% of the credits. MASSIE was brought in to shore up the initial study and to take the client to appeals. The client sustained 100% of the credits as a result of our council.
- A Boston-based company was facing an IRS exam after computing R&D tax credits in-house. MASSIE was hired to do a reverse-audit over a three-week period, providing the client with a roadmap of what the IRS would likely find during exam. MASSIE then worked with the client to fix those items in advance of IDRs being issued. The net result was a successful outcome for the client, and MASSIE did a full-phased outsource of the R&D study for the client the following year.
- An Atlanta-based company had an internal use software claim. MASSIE was hired to do the initial study, after other firms found the area too risky. MASSIE was able to do the study, and later defended the work done at exam, resulting in a no-change audit.
- A Nashville-based company hired MASSIE to assist in an appeals matter after disallowance by the exam team. MASSIE was able to work with appeals and resolve the issue favorably.