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A California-based S corporation operates in California and New York. The sole shareholder materially participates in the business and receives W-2 wages. In 2023, the S corporation claimed the federal R&D credit under IRC §41 and reduced wage expense accordingly. How do California and New York conformity rules affect: 1. the deductibility of wages, 2. the availability and treatment of the R&D credit, and 3. the shareholder's qualified business income deduction under IRC §199A?
Answer Sources (20) Steps
PlanningIn Progress
First, query taxes_federal_bills for "2023 amendments to IRC Section 41 and Section 199A." Next, retrieve IRC Section 41 (year=2023) via taxes_federal_internal_revenue_code...
Federal Tax BillIn Progress
14 scribed under section 3402(a) of the Internal Revenue Code 15 of 1986 for taxable years beginning after December 31, 16 2025...
IRC Code (2023)In Progress
Title 26— INTERNAL REVENUE CODE § 41. Credit for increasing research activities (a) General rule For purposes...
Answer Sources (20) Steps

Multi-State R&D Credit Conformity and QBI Effects (CA & NY) — 2023 Facts

Federal backdrop (what the S corporation did in 2023)

The federal research credit equals "20 percent of the excess" of current-year qualified research expenses (QREs) over the base amount, plus amounts for basic research and energy research consortia, and QREs include in-house "wages" for "qualified services," supplies, and certain computer costs.1234

For the shareholder's § 199A, the deduction equals the lesser of the "combined qualified business income amount" or 20% of taxable income above net capital gain, with W-2 wage/UBIA limitations potentially applying at higher income levels.5

1) Deductibility of wages at the state level

California

California computes a separate R&D credit under Cal. Rev. & Tax. Code § 23609 (corporations) by reference to IRC § 41 but with California-specific modifications and requiring that "qualified research" be conducted "in California."678

New York

New York personal income tax for S corporation shareholders starts from federal adjusted gross income. Because the S corporation's ordinary income flows into the shareholder's federal AGI, that reduction typically carries into New York.1112

2) Availability and treatment of the R&D credit

Federal

Structure, definitions, and recordkeeping for the credit and QREs are governed by IRC § 41 and Treas. Reg. §§ 1.41-1 through 1.41-4.13141516

California

California provides its own R&D credit under Cal. Rev. & Tax. Code § 23609, determined "in accordance with Section 41 of the Internal Revenue Code" but with California-specific rates and rules.171819

3) Shareholder's § 199A deduction (QBI) effect

Federal: The § 199A deduction is calculated at the shareholder level based on QBI, subject to wage/UBIA and taxable income thresholds.2324

California and New York do not offer state-level QBI deductions.2526

In Essence

  • Keep the federal wage reduction tied to the § 41 credit; in California, compute a separate § 23609 credit on California research.
  • The shareholder's federal § 199A deduction stays federal-only.
Sources
1IRC § 41(a) 2IRC § 41(b)(2)(B) 3Treas. Reg. § 1.41-1 4Treas. Reg. § 1.41-2 5Cal. Rev. & Tax. Code § 23609 6N.Y. Tax Law § 43 7IRC § 199A(a)

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