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Inside IRS Form 6765 for the R&D Credit

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The Research Tax Credit for federal purposes has been around since 1981, and the form to report qualified research expenditures has been in existence since at least 1990. 

Form 6765, which has changed dramatically from its predecessor, still asks for information on the qualified research expenditures that a taxpayer is including as part of the research credit. 

“The form has always said, ‘Tell us your wages, your supplies, your contract research and your cloud computing expenses and give us the total,’ said Michelle Abel, a principal at Baker Tilly and leader of the Top 10 Firm’s credits and incentives group nationwide, with a focus on the research credit.

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“The big difference now is that there’s a lot more detail being required at the time of filing this form,” she explained. “These are qualified research expenditures, or QREs. The understanding was always that you’re only putting QREs on your Form 6765 that relate to qualified research activities. But the form never had any place to provide detail about what all those activities were.”

“The idea was that you file the form, but you’ve already done the work to document what your qualified activities were, and how those dollars that you’re reporting on the form relate to those qualified activities,” she continued. “And if a taxpayer was under IRS exam a few years down the road and they didn’t have this documentation already put together, they would have to scramble to put it together or try to dig it up and recreate the documentation that they should have had back in the year they filed it. And that can be difficult because sometimes the employees that are involved are gone, and the records aren’t there anymore. We always recommended having the documentation in place, but the form never before required it. So taxpayers could do their calculations, file the credit and choose not to put any documentation in place if they wanted to gamble and hope they wouldn’t be involved in an exam, or that they would have time to pull the information together.”

There are two additional pages on the form that, in essence, inform the taxpayer that they need to specify the development activities that they were involved in and get it on the form when they file their tax return. 

“The development activities are called ‘business components,'” said Abel. “For example, a company develops one product every year. They do new research and development to improve that product. Then they really have one business component — it’s that product and the improvements that they make each year. In contrast, a software company that has 10 different types of software, and they’re doing a number of different development efforts on each of those 10 different software products to improve them each year. That company might have anywhere from 10 to 30 business components. So some companies could have 100 business components every year.”

In the aerospace and defense industries, for instance, there could be hundreds of different things going on in any one year that are all qualified business components, Abel observed. 

“They want you to list what are all of the business components that you are engaged in during the current tax year you are filing, and they want you to break out the actual name and unique identifier of those business components,” she said. “They want to know the wages, the supplies, the contract research expenses and the cloud computing expenses for each business component. Previously the taxpayer could just combine all those dollars and put them on the form. Now they really need to have all of their ducks in a row in terms of which dollars relate to which business components, and have them ready to go in detail on the return.”

Direct wages and supporting wages were never a part of the form, but now the IRS wants to know them, Abel noted: “They need to say OK, for the wages that are being included, what portion relates to officers of the company? When the IRS sees officers’ wages included, it’s one of the first things they ask — are they really in the trenches with their sleeves rolled up, or are they more of an administrative person? That’s one of the first things they want to dig into and scrub if you’re under exam.”

The breakout that Abel mentioned is not required until the 2025 form is submitted. However, for 2024, a taxpayer is required to give the number of business components that they’re looking at: “Is it the one business component, or 30 business components or 500 business components that they’re including in their calculations? And the officers’ wages that were included as part of the wage QRE, whether the taxpayer acquired or disposed of any major portion of their trade or business during the tax year. I’m not surprised that the IRS is requiring these for 2024, since they’re some of the first questions that the IRS will ask about when a taxpayer is under IRS exam.”

Two new questions are required for 2024, Abel noted: Did the taxpayer include any new categories of expenses for the current year that that they are including as QREs, and did the taxpayer determine any of the QREs following the ASC 730 Directive method (a method certain large business taxpayers can use when identifying QREs based on financial statement R&D amounts).

“Tax year 2025 is when all taxpayers are required to adopt that additional level of detail which asks taxpayers to list the wages, the supplies, the contract research expenses and the cloud computing expenses for each business component,” she warned.

Some taxpayers will not be required to fill out Section G, which is the breakdown of business component by business component, according to Abel: “Any business with total QREs equal to or less than $1.5 million and gross receipts equal to or less than $50 million will not have to complete Section G, and also any taxpayer who fits the definition of a qualified small business when looking at whether or not they can apply their credits against payroll taxes. Both of these can ignore Section G.”

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AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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