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Form 6765 Section G: What Changes for 2026 R&D Credit Claims

For business owners with research and development activity, the Form 6765 Section G requirements depend on the tax year: Section G is optional for tax years beginning in 2024 and 2025, and required for tax years beginning in 2026, subject to exceptions. For taxpayers completing it, the IRS says detailed business-component information must cover 80% of total qualified research expenses, with a limit of 50 components.

The change can feel like another layer of tax reporting, especially when research spans several products, processes, or software projects. The key is to connect each business component to the research work and expenses behind it, rather than treating the credit as one company-wide figure.

This article explains what Section G asks for, how the 80% threshold and 50-component cap work, and how controlled-group reporting can affect the calculation. You’ll also see how the requirements differ by tax year, which taxpayers may qualify for an exception, and what documentation can help you and your CPA prepare an accurate claim.

Key Takeaways

  • Learn how to organize research activity and related expenses by business component, with documentation that supports the work performed.
  • See how controlled-group membership can affect which expenses count toward reporting thresholds.
  • Understand when an original return may qualify for an exception and why amended claims are treated differently.
  • Compare the filing rules across tax years so you can prepare the right information for your CPA.

What Is the 80%/Top 50 Rule for Form 6765 Section G?

Section G adds business-component detail to the research credit claim. According to the Internal Revenue Service, taxpayers completing Section G must provide qualitative information for business components that make up 80% of total qualified research expenses, with a limit of 50 components. The Form 6765 Section G requirements focus on describing the research, not merely reporting a company-wide expense total.

Sections A through F calculate or report credit-related figures and elections; Section G requests explanations tied to individual business components. A component may be a product, process, software, technique, formula, or invention developed or improved by the taxpayer. List components in descending order of qualified research expenses, then report the remaining components together as “Aggregate Business Components.”

Section G supports the four-part test under IRC §41. Qualified research must be technological in nature, seek a permitted business purpose, address uncertainty, and use a process of experimentation. The component description should connect those elements to actual research activities. For example, explain the uncertainty, what the team tested, how it tested the idea, and the results.

Keep gross-receipts tests distinct. A business generally needs average annual gross receipts of no more than $50 million for the prior three tax years to meet the stated small-taxpayer threshold. A separate qualified-small-business test uses less than $5 million in current-year gross receipts and no gross receipts before the five-year period ending with the current tax year. These tests do not replace the component reporting calculation.

For each component, retain records linking research activities to wages, supplies, computer time-share costs, and contract research expenses. The credit is figured on Form 6765; eligible small businesses may also use it for a payroll tax credit. Refund claims postmarked after June 18, 2024 must identify business components and research activities, and provide a qualified research expense breakdown. An R&D credit analysis can help organize the technical record supporting the claim.

Section G business-component reporting

Section G organizes the claim around individual projects, while the payroll tax election may affect whether a qualified small business completes this section. This distinction matters for startups preparing their credit election and tax return together.

Business-Component Information

For components reported separately, list them in descending order by qualified research expenses. Report the remaining components together as “Aggregate Business Components.” This ordering shows how the listed components relate to the claim’s total, while the aggregate entry captures work that is not detailed individually.

For each listed component, provide the qualitative information requested on the form. Describe it distinctly from other projects, even when the same team worked on them. For example, a software startup should distinguish separate development efforts involving different components, rather than combining all company research into one entry.

Required Information for Each Line

Each Section G entry calls for component-level information and associated qualified research expense amounts. Describe the research work for that component, the uncertainty addressed, the testing approach, and the results. Use consistent project identifiers so each entry can be matched to the company’s internal project records.

A qualified small business under IRC §41(h)(3) isn’t required to complete Section G if it checks the box to claim the reduced payroll tax credit. That exception is tied to the election, not simply to being a startup or having limited research activity.

The payroll tax credit election lets an eligible qualified small business apply the elected credit against payroll tax liability. Notice 2017-23 addresses this election. Before filing, align the Form 6765 election and checkbox with payroll tax reporting, and have your CPA confirm the business meets the qualified-small-business requirements. A business that doesn’t make this election should assess Section G separately under the rules for its tax year.

Clarification on qualified research expenses and group reporting

Controlled-group reporting requires taxpayers to distinguish group-level eligibility tests from each member’s own return data. This matters when related companies conduct research but file separate federal returns.

According to the Internal Revenue Service, a taxpayer may be exempt from Section G if controlled-group QREs are no more than $1.5 million, average annual gross receipts for the prior three tax years are no more than $50 million, and the taxpayer reports a research credit on an original return. The conditions apply together. A taxpayer that fails one condition cannot rely on this exemption through the other conditions alone.

For members of a controlled group filing separate returns, calculate each member’s component reporting using that member’s own qualified research expenses, not the group’s combined expenses. For example, a parent and subsidiary should keep distinct expense totals for their respective returns, even if they share research staff or facilities. Group totals remain relevant to the exemption test, but do not replace the reporting figures for each separate filer.

The IRS’s June 18, 2025 clarification addressed qualified research expenses and group reporting. Apply that member-level distinction when reconciling each company’s Form 6765 to its own return and project records. If employees or costs serve more than one group member, the records should show which entity’s research activity and claim the amounts support. This helps avoid treating consolidated operations as one reporting unit when entities file separately.

Before filing, prepare a group schedule showing each member’s return status, QRE total, and gross-receipts information used for the exemption analysis. Compare that schedule with the individual Forms 6765 and the group’s controlled-entity records. For tax years beginning in 2026, this reconciliation can identify which members need component details and which meet the original-return exemption conditions. Keep the analysis with the return workpapers so the group-level test and member-level reporting can be followed independently.

Section G filing requirements by tax year

For a filing-year review, match the return’s tax year to the correct Form 6765 instructions, then reconcile the form with the taxpayer’s workpapers. This catches mismatches before the return is submitted.

Filing-Year Applicability

Filing-year applicability means using the form and instructions that correspond to the tax year reported on the return. A return filed later may still relate to an earlier tax year. Record the tax year’s beginning and end dates in the workpapers, then ensure the return preparer uses the matching form version.

For a fiscal-year filer, do not assume that the calendar year of filing determines which instructions apply. Use the tax year’s start date as the reference point, and have the preparer note the form version in the return file.

Who Must Complete Section G

Taxpayers claiming the research credit should determine whether their return requires Section G under the rules for that tax year. Document the decision in the filing workpapers, along with the basis for any exception claimed.

Before filing, compare the Section G entries with the credit calculation and the business’s source records. Check that component descriptions are consistent across the form, project schedules, and supporting files. If a component was acquired, discontinued, or reorganized during the year, document the reporting treatment rather than leaving differences unexplained.

Current-Year Instructions and Updates

The finalized Instructions for Form 6765 were released February 5, 2026. Use that version for applicable 2026 tax-year reporting, and review its line-specific directions before finalizing the return. Instructions clarify what information belongs in each field, so a prior-year workpaper template shouldn’t substitute for the current form guidance.

As a final check, confirm that the form version, tax-year dates, election entries, and totals agree with the filed return. Keep a copy of the instructions with the workpapers. This record helps the CPA explain how the reported information aligns with the applicable filing-year guidance.

Engineered Tax Services: Cost Segregation

Engineered Tax Services helps business owners connect qualifying research activities to the technical work and expenses reported for R&D tax credits. If your team is preparing for Section G reporting, we can help document how each business component was developed or improved, what uncertainty the work addressed, and how testing informed the results.

This support is useful when research spans engineering, software, manufacturing, or construction projects and the project records don’t clearly connect activities with qualified research expenses. We work alongside your CPA, providing engineering analysis and documentation for the credit claim. Our role is not to replace your tax preparer, but to support the technical substantiation behind Form 6765.

To discuss your research activities and Section G documentation with Engineered Tax Services, contact our team.

Prepare your research record for the next filing

Use the upcoming filing cycle to align project records with how your business conducts research. Ask project leads to identify the work performed, the technical questions addressed, and the records connecting those activities to expenses. Then share that material with your CPA so the technical analysis and tax reporting present a consistent account.

The Form 6765 Section G requirements are most manageable when business-component information is part of regular project documentation, rather than assembled only during return preparation. That preparation also gives your team a practical opportunity to resolve gaps in project descriptions and expense tracking before the filing work begins.

Engineered Tax Services works with business owners and their CPAs on the engineering support behind R&D tax credit claims. If you’d like to discuss how that support could fit your process, contact Engineered Tax Services. A clear working relationship with your advisor can help connect the research record to the tax return.

Frequently Asked Questions

What is Section G?

Section G is the part of Form 6765 that records research-credit information by business component. It helps connect a product, process, or other component to the research work and expenses claimed. For example, a manufacturer can distinguish testing for a newly developed production process from research on a separate product. That component-level view makes the claim easier to trace back to project records.

If Section G is optional in 2025, why complete it?

Completing Section G voluntarily for a 2025 tax year can help a business test whether its project records support component-level reporting before the requirement applies. A software company, for example, can identify whether its time records and project descriptions distinguish separate product-development efforts. The exercise also gives the CPA and technical team a chance to resolve inconsistencies while preparing the return.

What is Section G of IRS Form 6765?

Section G is a reporting section within IRS Form 6765, the form used to figure and claim the credit for increasing research activities. It focuses on which business components generated qualified research expenses, rather than only presenting the credit calculation. A component may be a product, process, software, technique, formula, or invention developed or improved by the taxpayer.

What are the eligibility rules for claiming the research credit on Form 6765?

Under IRC §41, qualified research must be technological in nature, have a permitted business purpose, address uncertainty, and involve a process of experimentation. These elements apply to the research activity, not simply to an industry or job title. For example, developing software can qualify only when the actual work meets the test. The taxpayer also needs records connecting eligible activities and expenses to the claim.

What records and documentation should taxpayers keep for Section G?

Keep project descriptions, test plans, design or technical records, results, and records connecting employee work to each component. For example, a manufacturer could retain production-process test results alongside employee time records and supply invoices. The records should show the technical uncertainty, what the team tested, how it tested the approach, and what it learned. Consistent project names across records and Form 6765 can help with traceability.

What are the filing deadlines and electronic filing requirements for Form 6765?

Form 6765 is filed with the tax return claiming the research credit; Section G does not create a separate filing deadline. The applicable deadline depends on the return type and filing circumstances, so coordinate the form with the return’s due date and any extension. Electronic submission depends on the return’s filing method and current IRS instructions. Amended refund claims require their own supporting information.

Article by

Heidi Henderson

Heidi Henderson is Chief Marketing Officer and a Senior Tax Consultant at Engineered Tax Services. She holds a master's degree in accounting and tax, spent years in private accounting for commercial real estate, development, and construction companies, and has worked directly with federal lawmakers on how tax incentives are structured. She's also a real estate investor and hosts the SlashTax podcast, where she breaks down tax strategy in plain English for investors, business owners, and CPAs.

Disclaimer

This article is general information, not tax or legal advice. Tax rules change, and how they apply depends on your specific facts. Talk with your CPA or tax advisor before acting on anything here.

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