R&D Tax Credit Insights & Analysis

Does Amending for R&D Credits Trigger an IRS Audit? What the Evidence Says

The McFerrin Decision Redefined “Research” for the R&D Tax Credit

ERC & PPP Loans: Can I Claim Both?

Debunking Section 174 Amortization Myths: Avoid R&D Tax Pitfalls

The One Big Beautiful Bill Act (OBBBA), signed into U.S. law on July 4, 2025, repeals Section 174 amortization for domestic R&D expenses, restoring immediate expensing starting in 2025. This change boosts cash flow, strengthens the value of Section 41 R&D tax credits, and supports U.S. businesses investing in innovation. But myths are spreading—about retroactive refunds, foreign R&D, software development, audits, and double-dipping under Section 280C. In this blog, Strike Tax Advisory debunks the top misconceptions, explains who qualifies for retroactive expensing (including the $31M small business threshold), and shows how startups and established companies can maximize credits, deductions, and hiring potential under OBBBA. If you’re searching for clear answers on “OBBBA Section 174 repeal,” “R&D tax credit myths 2025,” or “how to claim retroactive R&D deductions,” this guide breaks it down step by step.

Arizona's Competitive Research and Development Tax Credit

Did You Skip R&D Tax Credits in 2022-2024? Now is the time to reverse that decision.

Many companies skipped R&D tax credits in 2022–2024 due to Section 174 amortization. Learn how the retroactive law change allows amended returns, potential refunds, and key deadlines before they expire.

R&D Tax Credits and OBBBA: Five Costly Mistakes to Avoid When Filing Retroactive Claims

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

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.

TCJA and the Resulting Tax Implications for R&D Companies

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.

Section 174 Repeal: Big Win for SMEs in Senate Tax Reform

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.

Pending 2025 Tax Bill Promises Section 174 Repeal

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