Transcript Slide 1
Qualified Therapeutic Discovery
Project Tax Credit
Presented by: Jason Brown, CPA
Date: May 10, 2010
Qualified Therapeutic Discovery Project Credit
Before the 2010 Health
Care Act, the only credits
available for drug
development were R&D
and orphan drug credits.
The QTDP credit is equal
to 50% of the “qualified
investment” for any
“qualifying therapeutic
discovery project” of an
“eligible taxpayer”.
What is an Eligible Taxpayer?
An “eligible taxpayer” employs no more than 250
employees in all businesses at the time of the
submission of the application.
What is a Qualified Therapeutic
Discovery Project?
A qualified discovery project is designed to:
– Treat/prevent disease or conditions by
conducting pre-clinical activities, clinical trial
studies or research for securing approval
under the Public Health Service Act 351§(a);
– Diagnose diseases/conditions or determine
molecular factors related to companion drugs
and diagnostics to guide therapeutic
decisions; or
– Develop a product, process or technology to
further the delivery or administration of
therapeutics.
What is a Qualified Investment?
A “qualified investment” is the total costs in the
tax year for expenditures necessary for and
directly related to the conduct of a “QTDP”.
An investment is considered a qualified
investment if made in 2009 or 2010.
The credit still applies even if the product is not
placed in service until after 2010.
Excluded Costs
Excluded Costs:
– Remuneration for CEO
– Interest expense
– Facility maintenance
Mortgage or rent
payments
Insurance payments
Utility and maintenance
– G & A expenses
Ineligible Investments
A credit is not allowed for:
– Bonus depreciation investments
– Investments funded by treasury grants
– Investments financed with non-qualified non-recourse
debt
– Investments in property that is:
Predominantly located outside of the US;
Primarily used for non-transient lodging; or
Used by governmental entities or by foreign
persons.
Certification Program
By May 21, 2010, IRS, in conjunction with
the Secretary of Health and Human
Services, must establish a QTDP credit.
The Treasury Department (TD) must
approve or deny any application within 30
days of submission.
The application can include a request for
an allocation of credits for both 2009 and
2010.
Certification Program - What’s the Catch?
The total credits that can be
allocated under the program
cannot exceed $1 billion for the 2
tax years.
Companies will need to apply
and compete with each other for
the credit.
The application will need to
include detailed documentation
for all allowable expenditures.
Apply early because once the
money is gone, the deal is over!
Criteria Used to Award the Credit
In determining qualifying projects, the TD will consider the
projects’ potential to:
– Result in new therapies to treat unmet need or to
prevent, detect, and treat chronic illness;
– Reduce long-term health care costs in the United
States; or
– Significantly advance the goal of curing cancer within a
30-year period.
Projects must also have the greatest potential to:
– Create and sustain (directly or indirectly) high quality,
high-paying jobs in the US; and
– Advance US competitiveness in life, biological, and
medical sciences.
Other Restrictive Rules
Other restrictive rules include:
– Recapture of the credit if property is disposed of or
ceases to meet credit requirements
– Reduction in basis for QTDP credit allowed in relation
to property subject depreciation
– Denial of deductions where double benefit
– Denial of research credit or orphan drug credit when
taking QTDP credit
Grants in Lieu of Credit for QTDP’s
If a company does not have a tax liability, it
could elect to apply for a grant instead of a
credit.
The TD will provide guidance on how to elect a
grant instead of a credit.
The grant will not be taxable.
Similar to the credit, the grant will be in the
amount of 50% of the costs related to a qualified
investment in a QTDP.
Applying for a Grant
An application for a grant under the 2010 Health Care
Act for a tax year beginning in 2010 must be submitted:
– Not earlier than the day after the last day of that tax
year; and
– Not later than the due date (including extensions) for
filing the federal tax return for that year.
Timing of the Grant Payment
The TD must pay the grant amount during the 30-day
period beginning on the later of:
– The date of the application; or
– The date the qualified investment is made.
In the case of investments of an ongoing nature, the TD
will issue regs determining when payments will be made.
What Entities Are Not Eligible for a Grant?
The TD cannot make any grant under the 2010
Health Care Act to:
– Any federal, state, or local government;
– Any tax-exempt organization;
– Any entity considered to be a clean
renewable energy bond lender, a cooperative
electric company, or a governmental body; or
– Any partnership or other pass-through entity
with an owner that falls within any of the
categories above.
What Should You Do Now?
Do not wait! This is not too good to be true.
Draft applications that are properly documented and
that clearly justify expenditures.
Make sure to show investments on a project-byproject basis.
How Can We Help?
We can assist you with:
Identifying qualifying projects
Capturing eligible costs
Collecting appropriate
support
Preparing and submitting
applications for the credit or
grant
Providing audit defense as
needed