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The IRS on February 6 issued revised instructions for Form 6765 (Credit for Increasing Research Activities). The revised instructions reflect recent changes to the treatment of domestic research or experimental (R&E) expenditures made by the One Big Beautiful Bill Act (OBBBA) under new Section 174A, as well as the IRS’s continued evolution of research credit reporting requirements compared to the prior instructions (Rev. January 2025, as clarified in June 2025).
As revised, the instructions reflect aspects of prior IRS guidance, including concepts addressed in the June 2025 clarification related to controlled group member-level reporting of qualified research expenses (QRE).
The revised instructions will influence how companies compute and document the research credit, which potentially could affect estimates of computations and IRS examinations. Importantly, the business component information that is reported in new Section G remains optional for 2025 and only becomes mandatory for 2026 tax years, with exceptions for certain filers.
Companies can use the revised instructions as a practical reference point for assessing readiness to comply with reporting obligations imposed by Section G in 2026 and for determining the level of voluntary disclosure of business component information, if any, for the 2025 tax year. The impact of these instructions should be evaluated together with other changes to the landscape, such as other provisions of the OBBBA.
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