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.

Plastics Industry R&D Opportunities

April 8, 2022

Jonathan Cardella

Proposed Bipartisan Legislation To Fix R&D Expense Treatment and Child Tax Credit

October 19, 2022

Jonathan Cardella

R&D Tax Credits and OBBBA Benefits

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

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.

R&D Tax Credits for Startups and Small Businesses: What You Need to Know

May 14, 2024

Jonathan Cardella

R&D Yields Significant Returns in the Plastic Injection Molding Industry

May 25, 2022

Section 174 Amortization Repeal in 2025: Boosting R&D Tax Credits

March 12, 2025

Jonathan Cardella

As of March 05, 2025, the end of Section 174 amortization is plausible but not locked in. Monitor the Ways and Means Committee’s work this Spring—draft text could drop by May 2025. Prep for two scenarios: a 2026 start (plan cash flow accordingly) or a 2022 retroactive win (audit past returns and prepare to amend).

Section 174 Relief: Estes’ R&D Bill Boosts Innovation in 2025

March 20, 2025

Jonathan Cardella

The Estes American Innovation and R&D Competitiveness Act offers a clear fix for Section 174’s innovation drag—immediate expensing, retroactive relief, likely resulting in major economic lift.

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.

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.

Small Businesses Set to Benefit the Most from R&D Tax Credits

Jonathan Cardella

TCJA and the Resulting Tax Implications for R&D Companies

January 17, 2023

Jonathan Cardella

Have Questions About R&D Tax Credits?

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