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November 12, 2021

Tuesday, November 30 | Examining implications of new Chief Counsel memorandum on research-credit-based refund claims (12 pm ET)

A Chief Counsel memorandum (20214101F) released October 15, 2021, addresses how taxpayers can establish a valid claim for a tax refund based on a research credit on an amended return. Amended returns that do not adhere to the memorandum may be rejected before the refund claim is examined, raising issues for taxpayers that have already filed research-credit-based refund claims, as well as taxpayers contemplating filing a claim.

Join our panel of research credit leaders for a discussion of the memorandum's contents and implications, including the potential consequences of compliance and non-compliance. Specific topics include:

  • Statutory and regulatory requirements for claiming a refund
  • Judicial decisions relating to research credit refund claims
  • Details and implications of Chief Counsel Memorandum 20214101F
  • Alternatives to complying with the memorandum
  • Recourse for taxpayers whose refund claims are rejected for failing to comply with the memorandum
  • Effects of the statute of limitations on refund claims in applying and responding to the memorandum

Date: Tuesday, November 30, 2021

Time: 12:00-1:00 p.m. EST New York; 9:00-10:00 a.m. PST Los Angeles

Registration: View archive here.


Alexa Claybon, Principal, National Tax Department, Ernst & Young LLP

Richard Fultz, Executive Director, National Tax Department, Ernst & Young LLP


Craig Frabotta, Principal, National Tax Department, Ernst & Young LLP

CPE credit offered: Up to 1.2 depending on actual duration. Recommended field of study: Taxes. Learning objective: Identify the statutory and regulatory requirements for filing amended return claims, federal courts' decisions relating to research credit amended return claims, and the content and implications of recent administrative guidance relating to research credit amended return claims. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

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