R&D Tax Credit Insights & Analysis

Inflation Reduction Act & CHIPS Act - How They Affect The R&D Credit

Internal Use Software and the R&D Tax Credit

IRS Delays Implementation of Form 6765 Changes for R&D Tax Credit Filers

On October 1, 2025, the IRS announced it is delaying the implementation of key Form 6765 changes (IR-2025-99). The extension gives taxpayers until March 31, 2026, to adapt to new reporting requirements for the R&D tax credit. Section G, which introduces detailed Business Component Reporting, remains optional for 2025 and will become mandatory in 2026 for most filers. The IRS also extended the 45-day transition period for perfecting refund claims through January 10, 2027. Businesses are encouraged to strengthen documentation and cross-functional processes now to stay compliant when the new standards take effect.

Is the R&D Tax Credit About to Be Fixed by Congress?

Landmark Tax Court Ruling Puts R&D Credits at Risk

The U.S. Tax Court’s December 2024 decision in Phoenix Design Group, Inc. v. Commissioner (T.C. Memo 2024-113) is a landmark case for engineering and professional services firms. The court denied R&D tax credit claims and upheld a 20% accuracy-related penalty under IRC §6662, citing insufficient contemporaneous documentation, lack of objective technical uncertainty, and no systematic process of experimentation required under §41(d). This ruling highlights the critical need for audit-ready documentation, activity-level time tracking, and applying the shrinking-back rule to protect R&D credit eligibility.

Many Startups Are Leaving Money on the Table

Maximize R&D Tax Savings with IRS Rev. Proc. 2025-28 and OBBBA

IRS Rev. Proc. 2025-28 implements the One Big Beautiful Bill Act (OBBBA), restoring immediate §174A R&D expensing, simplifying §280C elections, and opening a refund window for 2022–2024 tax years. Small businesses can file amended or superseding returns to recover cash, while larger companies gain streamlined compliance with automatic accounting method changes. This guidance marks a turning point after TCJA’s capitalization rules, offering clarity, cash flow relief, and planning opportunities for innovative taxpayers.

Most Software Development Qualifies for R&D Tax Credits

Net Operating Losses (NOLs) & the R&D Tax Credit

Patent Safe Harbor: Removing Uncertainty from R&D Tax Credit Claims

Pending 2025 Tax Bill Promises Section 174 Repeal

2025 tax bill draft document with Section 174 repeal highlighted for R&D tax relief.

Pharmaceutical Companies Reap Significant Tax Benefits: The Orphan Drug Tax Credit