Form 6765 Section G is now mandatory for most filers. Claims without project-level proof and all amended claims must answer it on the return.
SCOTTSDALE, AZ, UNITED STATES, October 1, 2026 /EINPresswire.com/ — Section G of Form 6765 becomes mandatory for most filers forFor decades the federal R&D tax credit worked the same way: filers reported a total, and the detail behind it stayed in the study until an examiner asked for it. Starting with tax year 2026 returns, the IRS is asking for that detail up front. Section G of Form 6765, optional for tax year 2025, becomes mandatory for most filers for tax year 2026 under the IRS announcement of October 1, 2025. [1] Strike Tax Advisory today published guidance on what the change means for companies that claim the credit.
Companies that are not tracking 2026 research activity by project during the year will need to reconstruct it before they can file.
What the IRS now requires
Section G requires a filer to list its business components, meaning its products, processes, software, or techniques, in descending order of qualified research expense until the list covers at least 80 percent of total QREs or 50 components, whichever comes first. [2] For every component on that list, the form asks for a name, a type, the software category where applicable, and the dollars attributed to it. Wages are split three ways per component: direct research, direct supervision, and direct support. Supplies, computer rental or lease, and contract research are each reported separately per component. Whatever is left is rolled into one aggregate line.
The wage split is where many companies are likely to find a gap. Payroll systems record who got paid. They do not record which project an engineer’s March was spent on, or whether her manager’s time that month was supervision or hands-on work. A study that produces a defensible total QRE number cannot, by itself, populate Section G.
“Section G moves the documentation question from the examination to the return itself,” said Tom Raudorf, Chief Operating Officer of Strike Tax Advisory. “Until now the form asked for totals and the detail lived in the study. Starting with 2026 returns, the detail is on the form, by project, with wages split three ways. Companies that build that record during the year will file cleanly. Companies that try to assemble it the week the return is due will find gaps they cannot close.”
Who is exempt, and who is not
Two groups may skip Section G on an original return: qualified small businesses electing the payroll tax credit, and filers with QREs of $1.5 million or less and average annual gross receipts of $50 million or less. [1] Both thresholds are measured at the controlled group level, so sister entities under common ownership count together.
The exemption covers original returns only. For tax years beginning in 2026 and later, any company claiming a new or increased credit on an amended return must complete Section G in full, regardless of size, including column 49(f): a written description, for each business component, of the information the research was intended to discover. [2] Refund claims for 2023 and 2024, years that generally remain open under the three-year rule of Section 6511, already require business component detail to be treated as valid claims. [2] [3]
Correction window ends January 10, 2027
Through January 10, 2027, the IRS is running a transition rule for refund claims: a company whose amended-return credit claim is missing required information receives a letter and 45 days to fix it. [1] The IRS has not announced an extension. Companies filing 2023 and 2024 lookback claims after that date should expect the same business component review with no correction window.
“The credit did not get smaller. The filing got more specific,” said Jonathan Cardella, Chief Executive Officer of Strike Tax Advisory. “Any company with an existing claim should have someone check whether its 2026 records can populate Section G. That is a one-hour question this fall and a multi-week problem at filing time. And any company sitting on an open lookback year should file it while the 45-day cure period still exists.”
The dates that matter
Tax year 2025 returns, filed in 2026: Section G optional for all filers.
Tax year 2026 returns, filed in 2027: Section G mandatory for most filers.
January 10, 2027: End of the IRS transition period giving amended-return filers 45 days to perfect a deficient research credit refund claim.
Amended returns: business component detail required for any open year; full Section G, including column 49(f), with no size exemption from tax year 2026.
Recommended steps before year end
Eligibility for the credit is unchanged and still turns on the four-part test under Section 41. [4] What changed is the proof. Strike recommends three steps before year end: confirming whether a controlled group clears the exemption thresholds; tagging research wages by project and by role for the remainder of 2026; and filing any open 2023 or 2024 claims before the transition window closes.
Strike’s 2026 Field Guide to R&D Tax Credits is available in the journal at striketax.com. [5] An R&D tax credit calculator is available at striketax.com/calculator.
About Strike Tax Advisory
Strike Tax Advisory is a leading research and development tax credit consultancy based in Scottsdale, Arizona. The firm pairs AI-assisted analysis with a team of R&D credit experts and has obtained more than $400 million in federal and state credits for clients across software, manufacturing, engineering, and beyond. Strike works on contingency; clients pay only when credits are delivered. Every study is built to populate Section G at the business component level and is backed by Strike Shield™, which provides unlimited audit defense at no additional cost and a 100% fee-back guarantee. Companies with prior R&D claims can request a no-obligation second opinion or Section G readiness review. More information is available at striketax.com or by calling 1-800-916-5165.
Media Contact
Strike Tax Advisory
info@striketax.com
1-800-916-5165
Sources
[1] IRS, IR-2025-99, October 1, 2025: https://www.irs.gov/newsroom/irs-extends-the-period-for-feedback-on-form-6765
[2] IRS, Instructions for Form 6765: https://www.irs.gov/instructions/i6765
[3] 26 U.S. Code Section 6511: https://www.law.cornell.edu/uscode/text/26/6511
[4] 26 U.S. Code Section 41: https://www.law.cornell.edu/uscode/text/26/41
[5] Strike Tax Advisory, 2026 Field Guide to R&D Tax Credits: https://www.striketax.com/journal/2026-rd-tax-credit-field-guide
Paul Sassano
Strike Tax Advisory
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