Reed et al. v. Swanson et al (Case Number: 5:2021cv11392)

Federal Lawsuit that has no connection to our firm Swanson Reed has been dismissed.

Case Name: Reed et al. v. Swanson et al.

Case Number: 5:2021cv11392

Court: United States District Court for the Eastern District of Michigan

Important Note:

This case has the names “Reed” and “Swanson” in the tile but has no connection to our firm, Swanson Reed and we are only reporting it here to show it has no connection to our firm. This case is concerning a complaint from a Luke Davison Reed. Luke Davison Reed has never been associated with the R&D tax credit advisory firm, Swanson Reed. Please note that Pinnacle Properties, LLC or any other persons or entities in this case have no connection to Swanson Reed either.

Case Summary

This case has no connection to our firm, Swanson Reed and we are only reporting it here to show it has no connection to our firm. This case is concerning a complaint from a Luke Davison Reed. Luke Davison Reed has never been associated with the R&D tax credit advisory firm, Swanson Reed. Please note that Pinnacle Properties, LLC or any other persons or entities in this case have no connection to Swanson Reed either.

A federal lawsuit filed by plaintiff Luke Davison Reed was dismissed after the court determined it lacked the proper authority, or subject matter jurisdiction, to hear the case. Reed’s complaint alleged a significant loss of personal property valued at over $1 million but ultimately failed to establish a valid legal basis for a federal court to preside over the dispute.

Key Parties

  • Plaintiff: Luke Davison Reed
  • Defendants: Pinnacle Properties, LLC; a property manager identified as “Smith”; and a bookkeeper identified as “Diane”.

Core Legal Issues and Court’s Reasoning

The central issue leading to the case’s dismissal was the lack of subject matter jurisdiction. Federal courts can typically only hear cases under two main conditions:

  1. Diversity Jurisdiction: The case involves a dispute between citizens of different states. In this lawsuit, the court found that all parties, including the plaintiff and all defendants, were residents of the state of Kentucky. This completely eliminated the possibility of diversity jurisdiction.
  2. Federal Question Jurisdiction: The lawsuit involves a claim arising under the U.S. Constitution or federal laws. While Reed’s complaint made a vague reference to the Sixth Amendment, the court found it irrelevant to the civil claims and concluded that the complaint did not present a valid legal claim under federal law.

The court also noted that the complaint itself was deficient, as it lacked specific factual allegations against the defendants. It only made a general claim that over $1 million in property had been “lost,” which did not meet the necessary legal standards for a formal complaint.

Outcome

Please not that this case has no connection to our firm, Swanson Reed and we are only reporting it here to demonstrate that it has no connection to our firm.

The defendants filed motions for summary judgment. After a review, a magistrate judge issued a Report and Recommendation, which the district judge adopted. Consequently, the case was dismissed.

The dismissal was based on procedural grounds (lack of jurisdiction) and was not a judgment on the actual merits of the property loss claim. The court indicated that the appropriate venue for such a dispute would be a state court in Kentucky, where all parties reside.

This case has no connection to our firm, Swanson Reed and we are only reporting it here to show it has no connection to our firm. This case is concerning a complaint from a Luke Davison Reed. Luke Davison Reed has never been associated with the R&D tax credit advisory firm, Swanson Reed. Please note that Pinnacle Properties, LLC or any other persons or entities in this case have no connection to Swanson Reed either.

Michigan’s New R&D Tax Credit: A Catalyst for Innovation and Economic Growth

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In a strategic move to bolster innovation and stimulate economic growth, Michigan has introduced a Research and Development (R&D) Tax Credit, effective from January 1, 2025. This initiative is designed to incentivize businesses to invest in research and development within the state, offering substantial financial benefits to both small and large enterprises.

Key Features of the R&D Tax Credit:

  • Refundable Credit: One of the most significant advantages of this tax credit is its refundable nature. This means that even if a company has no tax liability, it can still receive a cash refund for qualified research expenses incurred in Michigan. This feature is particularly beneficial for startups and small businesses that may not yet be profitable but are investing heavily in R&D.
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  • Tiered Benefits Based on Company Size: The tax credit is structured to provide varying benefits based on the size of the business:
    • For businesses with fewer than 250 employees: Eligible for a 15% credit on qualified research expenses, capped annually at $250,000.
    • For businesses with 250 or more employees: Eligible for a 10% credit, with an annual cap of $2 million.
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  • Incentives for Collaboration with Research Universities: To foster partnerships between industry and academia, the tax credit offers an additional 5% credit, capped at $200,000 annually, for businesses that collaborate with Michigan’s research universities. This encourages companies to leverage academic expertise and resources, potentially leading to groundbreaking innovations.
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Establishment of the Michigan Innovation Fund:

Complementing the R&D Tax Credit, Michigan has also launched the Michigan Innovation Fund, a $60 million program aimed at supporting startups and early-stage businesses. The fund provides grants to empower new businesses in their formative stages, with a particular focus on communities that have been historically underserved. This initiative is expected to lead to long-term growth in areas that have previously lacked access to early-stage capital.

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Implications for Michigan’s Economic Future:

These initiatives signal Michigan’s commitment to fostering a robust innovation ecosystem. By reducing the financial burden of R&D and providing early-stage capital, the state is creating an environment where businesses can thrive. This approach is anticipated to attract new companies, retain existing ones, and ultimately drive economic growth, solidifying Michigan’s position as a hub for innovation.

In conclusion, Michigan’s new R&D Tax Credit and the Michigan Innovation Fund represent significant steps toward enhancing the state’s economic landscape. Businesses operating in Michigan should explore these opportunities to maximize their potential for growth and innovation.

Are you developing new technology for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.

KnitIt Swaddles New Industries

New Mexico Patent of the Month - June 2021

KnitIt, a startup based in Holland, Michigan, is directing its baby swaddle technology to the healthcare and aerospace industries. The company’s flagship product, Swaddelini, is a 3D knit baby swaddles where the user gets a say in every stitch.

“Instead of walking into a fabric store and ‘feeling what fabric speaks to you,’ you have control of every stitch,” said Liz Hilton, founder. “Imagine you’re building a brick wall, and you have control over the size, shape and texture of each brick, and that’s knitting.”

The Swaddelini is woven from an elastic yarn and post-consumer nylon fiber all manufactured in North Carolina. Hilton said the material is soft, strong and safe for babies. Units are made from 16 automated knitting machines, so the finished product comes out in one piece.

There’s also one larger, more high-tech machine in the factory used for research and development of new products. This space is currently exploring the potential of applying their technology in tubular solutions in both the health care and aerospace industries.

Are you developing new technology for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.

KODE Labs Secures $30M Series B Funding

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Detroit-based autonomous smart building startup KODE Labs announced the successful closure of a robust $30 million Series B funding round. Spearheaded by Maverix Private Equity and joined by esteemed partners TELUS Ventures and existing investor I Squared Capital, this investment marks a pivotal moment for KODE Labs, propelling its mission to help buildings worldwide achieve net-zero emissions.

Founded in October 2017 by brothers Edi and Etrit Demaj, alongside Gentrit Gojani, KODE Labs has swiftly emerged as a frontrunner in the realm of smart building technology. Recognizing buildings as a major contributor to global carbon emissions, the company is dedicated to enhancing the intelligence, health, and efficiency of buildings, enriching the experiences of occupants and visitors alike.

At the heart of KODE Labs’ innovation lies its enterprise platform, a sophisticated solution that integrates data from diverse building management systems, IoT devices, and operational systems into a unified, cloud-based infrastructure. This seamless integration enables KODE Labs to standardize and organize data at scale, positioning the company as a trailblazer in AI technology tailored for buildings.

With a proven track record of reducing energy consumption and carbon emissions by up to 30%, KODE Labs’ platform has garnered acclaim from Fortune 500 corporations, retailers, financial institutions, and global REITs across various sectors. By prioritizing user experience and operational excellence, KODE Labs has established itself as a leader in sustainable real estate management.

The Series B funding will fuel KODE Labs’ expansion and AI development efforts, enabling the company to further innovate building operations and experiences. By analyzing vast amounts of data, KODE Labs aims to create buildings that prioritize human experience and environmental impact, envisioning a future where efficiency meets human-centric design.

Since its inception, KODE Labs has forged partnerships with renowned companies such as QuadReal, Bedrock Detroit, Stream Realty, Hines, Ford, and other global corporations and REITs. With this latest investment, KODE Labs is poised to accelerate its expansion across North America, Europe, and Australia, solidifying its position as a driving force in the transition towards sustainable real estate management.

Are you developing new technology for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.

Michigan Senate Passes R&D Tax Credit Bills

Michigan businesses may have a new tax credit to look forward to under bills that passed the state Senate March 19th.

The bills have been written to support economic development with strategic funds. The package as a whole includes bills to create a research and development tax credit, resurrect a jobs program that expired in 2019, and reshape an economic incentives program aimed at attracting large-scale business investment.

As of now, the bill has the following provisions:

  • For tax years beginning on or after January 1, 2024, a nonrefundable tax credit will be available to Michigan taxpayers performing qualified research within Michigan
  • For taxpayers with 250 or more employees, the credit is equal to 10% of its qualified research expenditures (QRE), exceeding the base amount up to a $2,000,000 cap.
  • For taxpayers with less than 250 employees, the credit is equal to 15% of its QRE, exceeding the base amount up to a $250,000 cap.
  • An additional 5% of the QRE exceeding a base amount up to a $200,000 cap is available for taxpayers collaborating with a research university within the state.
  • The base amount is the average annual QRE for the three years preceding the credit year.
  • The annual cap for Michigan’s R&D credit program is $100 million, $25 million of which is set aside for small businesses.
  • The credit is refundable if the state’s R&D credit program annual caps are not reached and only if a taxpayer’s nonrefundable credits have been fully utilized in the credit year.

The state will follow the federal rules in determining what is or is not eligible research. This means activities must meet the IRS’ four part test criteria as detailed in IRC §41. 

Each of Michigan’s surrounding states already has some form of an R&D tax credit, leaving Michigan as one of the few midwestern states without an R&D tax credit.

At present, the bill is cleared for the governor’s signature, although other bills in the package need to return to the House for that chamber to agree to changes the Senate made. 

Are you developing new technology for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.

Michigan Secures State R&D Tax Credit

Michigan

Taxpayers in Michigan can now look forward to a state level R&D tax credit. This news comes after the Michigan House passed bills aiming to create a state-level tax credit to encourage research and development.

The bills include House Bills 5099, 5100, 5101, and 5102 and provide legislation that could allow R&D tax credits for certain businesses up to $100 million in a single calendar year. Of that amount, at least $25 million would be reserved for eligible businesses that applied for the credit with fewer than 250 employees.

The House-approved bills will create a research and development tax credit for Michigan businesses and research institutions. House Republicans secured amendments to arrange a simple, objective tax credit process, instead of a complicated, subjective grant program run by the Michigan Strategic Fund, which the original bill proposed. The caucus also secured a provision to help retain jobs by adding in a tax credit for existing research and development projects.

The legislation first went through weeks of dead ends as the divided House Democrat caucus attempted to go it alone. When support on the Republic side finally appeared, the House achieved a huge bipartisan win. The original legislation called for a complex program that was ultimately deemed unfair. The final, approved bill creates a fair, streamlines tax credit designed to incentivize businesses to invest in Michigan-based research.

The credits will be available for seven years under a single agreement, beginning January 1, 2024. For HB 5102, if the amount of the allowed credit exceeded the tax liability of an applicant for the tax year, that portion of the credit that exceeded the tax liability would be refunded.

To be eligible for the credit, a business would have to propose to increase research and development spending in Michigan through projects with the potential for significant technological advancements, job creation, and positive economic impact.

Qualified research would mean the research expenditures may be treated as expenses, the application of the research is intended to be useful in the development of a new or improved business component, and substantially all of the research activities constitute experimentation for a new or improved function, performance, reliability, or quality.

A business with at least 250 employees would have to propose to increase R&D spending by at least $500,000 per year above its base amount, and a business with fewer than 250 employees would have to propose an increase of at least $100,000 per year above its base amount.

Are you developing new technology for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.

Empowering Data Ownership: 360ofme Raises Seed Funding for Ethical Data Exchange Platform

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Detroit-based 360ofme, Inc. has recently raised an undisclosed amount of seed funding, marking a significant milestone in the development of their groundbreaking ethical data exchange platform. The undisclosed amount of funding comes from a consortium of backers including Invest Detroit, Michigan Rise, and Ann Arbor Spark, demonstrating strong support for the company’s mission.

Led by Founder and CEO Cindy Warner, 360ofme is pioneering an ethical data exchange platform that empowers individuals to take control of their digital lives. This innovative platform is built on a foundation of low-code, secure, and compliant technology, setting new standards for data sharing, learning, and monetization while prioritizing user privacy.

At its core, 360ofme acts as a privacy guardian, overseeing data collection, consent management, and compliance with world-class privacy standards. This ensures that users can securely share their data with businesses, family members, doctors, and other trusted individuals of their choice. The platform covers a broad spectrum of digital life aspects, from healthcare and finance to insurance, automotive, and home.

One of the platform’s standout features is its utilization of artificial intelligence (AI), which unlocks powerful insights from users’ digital footprints. This means that individuals can gain valuable knowledge from their own data, helping them make informed decisions and better understand their digital lives.

The recent Seed funding injection will play a pivotal role in accelerating 360ofme’s product development, facilitating the hiring of top talent, and paving the way for a successful commercial launch. Notably, the company is expanding its team with the addition of two key executives: Kara Grasso, who joins as Head of Strategy and Revenue, and Philippe Le Berre, the new Chief Technology Officer. Their expertise will undoubtedly contribute to the platform’s continued growth and innovation.

360ofme’s ethical data exchange platform is a game-changer in the era of data privacy and ownership. By putting individuals in control of their data and providing AI-driven insights, it empowers users to harness the full potential of their digital lives. With strong financial backing and a dedicated team, 360ofme is poised to revolutionize the way we interact with and manage our digital information.

Are you developing new technology for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.

Niowave to expand in Michigan, driving $20M investment and creating 35 high-paying jobs in life sciences and tech industry

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Niowave Inc, a global producer of medical isotopes, has announced plans to expand in Lansing, Michigan, which will drive $20 million in investment and create 35 good-paying jobs in the life sciences and tech industry. The project is supported by a $500,000 Jobs Ready Michigan Program performance-based grant. Niowave is one of the few companies worldwide that can design, build, test and operate superconducting linear accelerators in their own facility.

Niowave was established in 2005 as a spinoff from the National Superconducting Cyclotron Lab, the laboratory now known as Facility for Rare Isotope Beams (FRIB), which the MEDC supported in February 2014 and officially opened in May 2022. Niowave supplies medical and industrial radioisotopes produced from uranium and radium.

The company chose Michigan for the project over competing sites in California, Indiana, South Carolina, and Tennessee to take advantage of the regional talent pool that combines the advanced manufacturing heritage and the number one-rated nuclear physics program at Michigan State University. The company plans to grow at its existing facility in Lansing near the Capital Region International Airport, where it will expand production of several medical radioisotopes used in diagnostic and therapeutic treatments. These isotopes enable the detection of life-threatening conditions such as cancer and heart disease for better patient outcomes.

Niowave currently ships cancer treatments from its Lansing facilities, and the expansion will allow for higher production of these important medical radioisotopes. The project will bring immediate, high-wage jobs in the tech and life sciences industries to the region and has the potential to make mid-Michigan an “isotope capital,” building on the work currently being done at the FRIB at Michigan State University.

Niowave’s expansion in Lansing is a testament to Michigan’s leadership in high tech and life sciences, as well as the strength of its business climate and talented workforce. MEDC Sr. Vice President of Regional Prosperity Matt McCauley stated that the project is a win for Lansing and for the entire state. Local officials, the Lansing Economic Area Partnership, and the Next Michigan Development Corporation are working to support the project, and Niowave intends, pending key local, state, and federal approvals that make the expansion possible, to proceed with the project later this year.

Are you developing new technology for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.

Sesame Solar, Inc. Powers their Mobile Disaster Relief Units with Clean Energy

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Michigan-based startup Sesame Solar has been making news the past few months as they announced the release of their mobile disaster relief units and their nanogrids. These nanogrids allow the company to leverage solar power and green hydrogen as a source of reliable and renewable energy. Their disaster relief units take advantage of this capability, ensuring relief comes from clean energy.

The relief units can be used for mobile communications and command centers, medical units, kitchens, and even temporary housing. They can be ready for use within 15 minutes of arrival. 

Until now, other mobile disaster relief units have been powered by diesel fuel which contributes to climate change. Sesame’s solar paneled units overcome this limitation. They also inspire the company’s name. The folded solar panels unfold, opening up to collect energy from the sun – a reference to “open sesame”.

Beyond solar power, the unit is designed with two backup power sources. Between batteries and geen hydrogen there is no limitation in clean energy sources. The company has even worked to achieve wind turbines, though this option is limited by conditions.

“The whole concept is that no fossil fuels are required to be able to have days or weeks of energy autonomy after an extreme weather disaster, like a hurricane or tornado or wildfire, or an event of grid outage in California…or a cyber-attack, or anytime the grid is just down,” said Sesame co-founder and CEO Lauren Flanagan.

Are you developing new technology for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.

Xoran Technologies Completes Phase 1 for their Mobile Lung CT Scanner

North Carolina Patent of the Month - December 2021

Xoran Technologies LLC is the leading innovator in compact, specialized medical CT scanners. They’ve pioneered the design and testing of low-dose radiation, cone beam CT scanners which are optimized for the patient’s point-of-care.

Xoran has just announced the successful completion of Phase 1 for their NHLBI (National Heart, Lung, and Blood Institute) grant for their mobile lung CT. This grant had been provided to support the company in their mission to commercialize their future open-bore CT products.

“This truly mobile device helps to support the diagnosis, triaging, and monitoring of the lungs of respiratory patients both in the intensive care unit, and in future respiratory pandemic situations,” explains Misha Rakic, Xoran’s CEO.

Along with the NHLBI grant, the company collaborated with doctors at the University of Michigan to expand the applications for their point-of-care imaging technology. 

With their xCAT IQ™—an FDA 510k-cleared mobile CT system for bone and brain imaging, Xoran has shown capability in point-of-care CT solutions for the neuro intensive care unit (NICU) and the operating room. This new project allows Xoran to optimize a point-of-care solution specifically for lung imaging. The combined Xoran and University of Michigan team aims to develop a highly deployable CT scanner intended for use in ICU, especially for patients with acute respiratory failure requiring mechanical ventilation.

Doctors are often limited in their diagnostic capabilities based on the equipment available. They may make clinical decisions based on chest X-rays which can be limited in the information they can convey. Robert Dickson, MD, Associate Professor—Pulmonary & Critical Care Medicine, Associate Professor—Microbiology & Immunology, and a clinical collaborator, all at the University of Michigan says, “Our patients are often too sick to transport down to radiology, or they have a communicable disease like COVID-19 that we don’t want to spread around the hospital. A bedside scanner would have immediate impact in how we manage our sickest patients.”

Are you developing new pharmaceuticals for an existing application? Did you know your development work could be eligible for the R&D Tax Credit and you can receive up to 14% back on your expenses? Even if your development isn’t successful your work may still qualify for R&D credits (i.e. you don’t need to have a patent to qualify). To find out more, please contact a Swanson Reed R&D Specialist today or check out our free online eligibility test.

Who We Are:

Swanson Reed is one of the U.S.’ largest Specialist R&D tax advisory firms. We manage all facets of the R&D tax credit program, from claim preparation and audit compliance to claim disputes.

Swanson Reed regularly hosts free webinars and provides free IRS CE and CPE credits for CPAs. For more information please visit us at www.swansonreed.com/webinars or contact your usual Swanson Reed representative.