R&D Tax Credit Insights & Analysis
Expert guidance on federal and state R&D tax credits from Strike Tax Advisory's team of CPAs, attorneys, and engineers.
Strike Tax Advisory publishes in-depth analysis on R&D tax credit law, IRS compliance, Section 174 developments, and OBBBA updates. Our journal is written by tax credit specialists who have delivered over $300M+ in credits for American businesses. All content references official IRS, Congressional, and legal sources only.
R&D Tax Credit for Agriculture: What George v. Commissioner Means for Row Crops and Livestock
May 4, 2026
Jonathan Cardella
The Tax Court ruling in George v. Commissioner confirmed agriculture qualifies for the R&D tax credit under Section 41. This guide breaks down how the framework extends from livestock to row crops, what the OBBBA Section 174A election windows are for small and large operations, and how Section 280C(c), Rev. Rul. 82-49, and Form 6765 Section G all interact for farm filers.

R&D Tax Credit for Companies Operating at a Loss: Why It Still Pays to Claim
April 7, 2026
Paul Sassano
Many business owners assume the R&D tax credit only matters when a company is profitable. The data says otherwise. This guide breaks down five ways loss-stage companies can capture real value from the credit, including retroactive cash refunds for prior tax years, a 20-year carryforward that banks credits for future profitability, a deferred tax asset that strengthens the balance sheet for investors and acquirers, and the payroll tax offset that delivers up to $500,000 per year in immediate cash to qualifying startups. Includes IRC references, worked examples, and the five most common mistakes loss-stage companies make.

R&D Tax Credits and OBBBA: Five Costly Mistakes to Avoid When Filing Retroactive Claims
November 26, 2025
Jonathan Cardella
The One Big Beautiful Bill Act (OBBBA), signed July 4, 2025, restores immediate R&D expensing under Section 174A, offering small businesses (≤$31M gross receipts) retroactive deductions for 2022-2024 via amended returns by July 6, 2026. This unlocks boosted Section 41 credits, NOL carrybacks, and refunds, but strict deadlines loom—e.g., November 15, 2025, for deemed 2024 elections. The guide exposes five pitfalls: skipping elections, siloed modeling, weak docs, wrong paths (amend vs. method change), and state conformity oversights, risking denials and 20% penalties. An example tech firm gains $1.5M+ in refunds by properly aggregating QREs and recalculating ASC credits. Best practices urge early eligibility tests, unified modeling, and pro consultations to maximize benefits before windows close.

R&D Tax Credits for Controlled Groups: Aggregation and Allocation Strategies
November 7, 2025
Jonathan Cardella
Many U.S. companies operate through multiple entities—holding companies, LLCs, subsidiaries, partnerships—which often triggers related‑entity rules under federal and state tax codes when it comes to claiming the R&D tax credit. Under IRC § 41(f) and Treasury Regulation § 1.41‑6, the Internal Revenue Service treats all entities in a qualifying “controlled group” as a single taxpayer. That means qualified research expenses (QREs) must be aggregated across group members and the resulting credit allocated among them on a compliant basis. Proper aggregation can unlock significant credit amounts—whereas failure to apply the rules correctly may result in disallowed credits, penalties, interest, and lost audit defenses. This article walks you through the four‑step process of aggregation and allocation: defining controlled‑group status (parent‑subsidiary, brother‑sister, combined), performing ownership and attribution tests, aggregating QREs, computing credit (Regular vs ASC methods), allocating among entities and filing the updated 2025 Form 6765 (with business‑component disclosure rules). Real time planning tips, common pitfalls and state‑credit considerations round out the guide so multi‑entity taxpayers can maximize opportunity while staying audit‑ready.

Section 174 Repeal: Big Win for SMEs in Senate Tax Reform
June 17, 2025
Jonathan Cardella
The Senate’s latest tax reform proposal includes a potential repeal of Section 174 amortization, offering SMEs the opportunity for immediate expensing of domestic R&D costs and retroactive tax benefits if enacted. This blog explains what will change, how SMEs can prepare, and what to watch for as the bill moves through Congress. Stay informed and ready to maximize your R&D tax savings if the new law is passed.

Section 174 Repeal Update: How OBBBA Section 174A Restored Immediate R&D Expensing
March 12, 2025
Jonathan Cardella
Section 174 amortization was repealed by OBBBA in July 2025. New Section 174A restores immediate domestic R&D expensing for tax years beginning after December 31, 2024. Eligible small businesses can amend 2022, 2023, and 2024 returns retroactively under Rev. Proc. 2025-28, with a deadline of July 6, 2026 or the Section 6511 statute of limitations, whichever is earlier. Here is what to do next.
Senate Approves OBBBA with Section 174 R&E Relief
July 1, 2025
Jonathan Cardella
The U.S. Senate has passed the One Big Beautiful Bill Act (OBBBA), delivering retroactive Section 174 R&E tax relief for small and medium-sized enterprises (SMEs). This landmark legislation allows qualifying businesses to immediately expense domestic research and experimental costs back to 2022, potentially unlocking millions in tax savings and boosting innovation. The bill now moves to the House of Representatives, where its retroactive relief provisions will be debated. SMEs are encouraged to consult tax experts, monitor legislative updates, and use StrikeTax’s R&D Tax Credit Calculator to maximize benefits. For ongoing updates and expert guidance, visit StrikeTax.com.
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