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.

Landmark Tax Court Ruling Puts R&D Credits at Risk
October 3, 2025
Tom Raudorf
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.

Maximize R&D Tax Savings with IRS Rev. Proc. 2025-28 and OBBBA
September 15, 2025
Jonathan Cardella
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.

Impact of IRC §280C Elections for R&D Tax Credit Claimants After OBBBA
September 9, 2025
Tom Raudorf
Understand the tax impact of making a §280C election when claiming the federal R&D tax credit. With the 2025 OBBBA reform and §174A expensing restored, businesses must carefully weigh the benefits of the reduced-credit election versus the gross credit with add-back. This guide breaks down compliance rules, real-world examples, and how to maximize federal and state tax benefits.
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