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Tax Court Expands RnD Credits for Livestock

Tax Court Expands RnD Credits for Livestock


By Jamie Martin

The US Tax Court issued a significant ruling that confirmed research and innovation in livestock production qualify for the federal Research and Development tax credit. This decision strengthened recognition of agriculture as an innovation-driven industry and provided long awaited clarity for producers. 

Previously, the Court had ruled that crop producers were eligible for RnD credits. The latest decision expanded that recognition to animal agriculture, confirming that livestock producers also engage in qualified research. Farmers and ranchers often experiment with new techniques to improve animal performance, health, and sustainability.

"The Tax Court deserves tremendous credit for carefully analyzing the science and innovation happening every day on American farms, ranches, and food science businesses" said John Dies, lead counsel in the George case. 

"These rulings recognize that agriculture is an innovation-driven industry where producers constantly experiment to improve yields, animal health, disease resistance, and sustainability. The Court's decisions solidify the legislative intent of promoting innovation for livestock and crop producers nationwide," said Dies.

The Court examined research activities focused on poultry production including efforts to reduce disease growth rates and enhance feed efficiency. These activities involved structured testing analysis and refinement over time. The Court determined that such work met all legal requirements for RnD credit eligibility.

Judges rejected the idea that livestock experimentation is routine or simple observation. Instead, they recognized that producers face technical uncertainty and rely on scientific methods to achieve better outcomes. This acknowledgment placed agriculture on equal footing with other research-based industries.

The ruling also addressed documentation standards. While some claimed credits were adjusted, the Court provided helpful guidance on what level of detail is expected. This clarification will assist producers in preparing stronger and more compliant claims in the future.

Another key part of the decision involved penalties. The Court ruled that penalties were not appropriate because the producer relied on experienced professional advice and acted in good faith. This reinforced the importance of using knowledgeable advisors when navigating complex tax rules.

"These Tax Court decisions represent a watershed moment for American agriculture," said alliant Strategic Advisory Board Chairman of Agriculture and Former U.S. Secretary of Agriculture Mike Johanns. "Our farmers, ranchers, and producers are among the most innovative in the world. The Court has rightfully recognized that this innovation deserves the same federal support as research in other industries."

Overall, the ruling ended with debate over whether farmers and ranchers qualify for RnD incentives. It confirmed that innovation in animal agriculture deserves federal support and plays a vital role in advancing food production efficiency and long-term sustainability.

Photo Credit: gettyimages-imaginegolf


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