IRS Extends Form 6765 Section G Comment Period Through March 2026

This blog post has been researched, edited, and approved by John Hanning and Brian Wages. Join our newsletter below.

Key Takeaways

  • Extended deadline - IRS extends comment period to March 31, 2026
  • Reduced compliance burden - Changes aim to alleviate taxpayer burden per IRS announcement
  • Transition period extended - Research credit claim period extended to January 10, 2027
  • Optional until 2025 - Section G remains optional for tax years beginning before 2025
  • Major compliance changes - Form requires 80% of total QREs by business component
  • Significant impact - IRS receives thousands of returns claiming research credit annually


The IRS extended the comment period for Form 6765 Section G through March 31, 2026 to alleviate taxpayer burden. 


This addresses widespread concerns about new reporting requirements. The extension gives businesses more time to prepare.


Most businesses see immediate benefits from this extension. The IRS also extended the research credit claim transition period through January 10, 2027. Companies have 45 days to perfect claims before final IRS determination.


Why Did the IRS Extend the Form 6765 Section G Timeline?

The IRS received comments from external stakeholders requesting additional time to share feedback. Business groups raised concerns about compliance complexity. The extension demonstrates IRS responsiveness to taxpayer needs.


Stakeholder feedback highlighted key issues:

  • Increased compliance costs - New requirements create substantial documentation burden
  • Implementation challenges - Taxpayers must provide substantial information not previously required
  • Resource limitations - Small businesses struggle with complex reporting requirements
  • Training needs - Tax professionals need time to understand new rules


The IRS extended the deadline for submitting feedback through March 31, 2026. Tax professionals can submit comments to lbi.rt.team@irs.gov. Use "Instructions for Form 6765" as the subject line.


What Makes Section G So Complex?

Section G requires reporting quantitative and qualitative information for each business component. This represents the most significant Form 6765 change ever. Companies must break down expenses by individual projects.


New reporting requirements include:

  • Business component names and types - Detailed project identification
  • Qualified research expenses - 80% of total QREs in descending order, maximum 50 components
  • Employee wage breakdowns - Direct research, supervision, support costs
  • Statistical sampling plans - Taxpayers using statistical sampling must attach plans
Section G Requirement Compliance Level Business Impact
Business Component Detail Mandatory 2025+ High complexity
80% QRE Reporting Top 50 components Significant tracking
Statistical Sampling Full documentation Professional assistance needed

How Will These Changes Affect Research Credit Claims?

The IRS receives thousands of returns claiming research credit involving hundreds of millions of dollars, with substantial examination cases consuming significant resources.


New requirements aim to streamline this process. Most businesses will face increased documentation needs.


The compliance burden affects different businesses differently. Stricter compliance measures add complexity to the claims process, potentially deterring smaller first-time claimants with limited resources. 


Large corporations have better resources to adapt.


Who's Exempt from Section G Requirements?

Section G is optional for Qualified Small Business taxpayers claiming reduced payroll tax credit, or taxpayers with total QREs of $1.5 million or less and gross receipts of $50 million or less. 


This provides relief for smaller companies.


Exemption criteria breakdown:

  • Qualified Small Business - Under Section 41(h)(1) and (2) definitions
  • QRE threshold - $1.5 million or less annually
  • Gross receipts limit - $50 million maximum
  • Payroll tax election - Must claim reduced payroll tax credit


Section G is optional for all filers for tax year 2024, allowing taxpayers time to transition. This gives businesses a full year to prepare systems.


What About Statistical Sampling Methods?

Taxpayers using statistical sampling must fulfill Section G requirements regardless of which business components are used for the sample and must attach their statistical sampling plan. 


This eliminates previous flexibility in sampling approaches.


Statistical sampling changes create new challenges. Companies using Rev. Proc. 2011-42 guidance must adapt. The IRS acknowledges some may use statistical sampling but still requires compliance irrespective of sample components. 


Professional assistance becomes essential.


What Should Businesses Do Now?

Taxpayers should begin planning for additional requirements for 2025, including ensuring they collect necessary information on research activities. 

Start documenting business components immediately. Review current tracking systems for compliance gaps.


Immediate action steps include:

  • Document current projects - Identify all qualifying business components
  • Review expense tracking - Ensure proper cost allocation by project
  • Assess compliance readiness - Evaluate documentation systems
  • Consult professionals - EngageR&D tax credit specialists early


Businesses should assess current R&D tracking processes and implement stronger documentation practices to avoid compliance issues. 


Technology solutions can streamline data collection. Many companies use automated expense tracking tools.


How Can Companies Prepare for Section G?

Technology tools help manage complexity. Many businesses leverage automated expense tracking tools and R&D tax credit software to streamline collecting and reporting data. 


These systems reduce manual work and improve accuracy.


Documentation best practices:

  1. Start early - Begin tracking business components now
  2. Use technology - Implement automated systems for data collection
  3. Maintain records - Keep detailed project documentation
  4. Get professional help - Work with experiencedR&D credit consultants
Preparation Area Timeline Priority Level
System Setup Immediate Critical
Staff Training Q1 2025 High
Process Testing Q2 2025 Medium
Full Implementation By year-end 2025 Critical

The extension provides valuable preparation time. The IRS extension offers a valuable opportunity for businesses and tax professionals to shape the future of research credit reporting. 


Use this time to optimize compliance processes.


What This Means for Your Business

The extension and modifications reflect the IRS's ongoing efforts to streamline the process and reduce taxpayer burden while helping taxpayers navigate the research credit claim process. 


Plan now to avoid last-minute compliance scrambles.



The research credit remains valuable despite increased complexity. Start documenting qualifying activities immediately to maximize future benefits.

2024 Tax Guide

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