Coordinated Issue Papers
The IRSs Large Business and International Division periodically publishes Coordinated Issue Papers in an attempt to identify, coordinate and resolve complex and significant industry wide issues by providing guidance to field examiners and ensuring uniform application of the law. Following review by the Office of Chief Counsel, these Issue Papers are published by the Commissioner, Large Business and International Division. As stated on the IRS website:
Although these papers are not official pronouncements on the issues, they do set forth the Service’s current thinking.
Here is a list of the Coordinated Issue Papers effecting the R&D Tax Credit:
ALL INDUSTRIES (Cross All Industry Lines)
Credit for Increasing Research Activities – Extraordinary Expenditures for Utilities – 05-09-2006
Credit for Increasing Research Activities – Qualified Research Expenses – 06-18-2004
Qualifying Wages under Section 41 in Determining the Tax Credit for Increasing Research Activities – Revised 02-16-1999
Research Credit – Internal Use Software – 08-26-1999
AIR TRANSPORTATION
Legally mandated R&E Expenses (also a Pharmaceutical issue) – 6-18-2003
DATA PROCESSING
Wages of Technical Writers and the R & E Credit – Revised 7-31-1992
PHARMACEUTICAL
Legally mandated R&E Expenses (also a Biotech issue) – 6-18-2003
UTILITIES
Membership Payments made to Industry-Created Research Organizations – 07-01-1993




