The IRS is extending the Research Credit claim transition period through January 10, 2026. (www.irs.gov/newsroom/irs-sets-forth-required-information-for-a-valid-research-credit-claim-for-refund) This means that for refund claims filed on or before January 10, 2026, taxpayers will be given a 45-day period to provide the required information for previously submitted claims.
In October 2021, the IRS initially set forth the additional information that taxpayers are now required to include for a Research Credit refund claim. (Chief Counsel Memorandum 2021401F) Taxpayers were given a transition period, during which taxpayers were given up to 45 days to perfect a previously submitted return. Since that time, the IRS has extended the transition period three times.
Pursuant to CCM 2021401F, as modified in subsequent guidance, taxpayers must provide the following information when claiming a Research Credit refund:
- Identify all the business components to which the IRC §41 Research Credit claim relates for that year;
- For each business component, identify all research activities performed; and
- Provide the total qualified employee wage expenses, total qualified supply expenses, and total qualified contract research expenses for the claim year.
This may be done using Form 6765, Credit for Increasing Research Activities.
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