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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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Accounting firms seeing increased profits

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Accounting firms are reporting bigger profits and more clients, according to a new report.

The report, released Monday by Xero, found that nearly three-quarters (73%) of firms reported increased profits over the past year and 56% added new clients thanks to operational efficiency and expanded service offerings.

Some 85% of firms now offer client advisory services, a big spike from 41% in 2023, indicating a strategic shift toward delivering forward-looking financial guidance that clients increasingly expect.

AI adoption is also reshaping the profession, with 80% of firms confident it will positively affect their practice. Currently, the most common use cases for AI include: delivering faster and more responsive client services (33%), enhancing accuracy by reducing bookkeeping and accounting errors (33%), and streamlining workflows through the automation of routine tasks (32%).

“The widespread adoption of AI has been a turning point for the accounting profession, giving accountants an opportunity to scale their impact and take on a more strategic advisory role,” said Ben Richmond, managing director, North America, at Xero, in a statement. “The real value lies not just in working more efficiently, but working smarter, freeing up time to elevate the human element of the profession and in turn, strengthen client relationships.”

Some of the main challenges faced by firms include economic uncertainty (38%), mastering AI (36%) and rising client expectations for strategic advice (35%). 

While 85% of firms have embraced cloud platforms, a sizable number still lag behind, missing out on benefits such as easier data access from anywhere (40%) and enhanced security (36%).

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Accounting

Private equity is investing in accounting: What does that mean for the future of the business?

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Private equity firms have bought five of the top 26 accounting firms in the past three years as they mount a concerted strategy to reshape the industry. 

The trend should not come as a surprise. It’s one we’ve seen play out in several industries from health care to insurance, where a combination of low-risk, recurring revenue, scalability and an aging population of owners create a target-rich environment. For small to midsized accounting firms, the trend is exacerbated by a technological revolution that’s truly transforming the way accounting work is done, and a growing talent crisis that is threatening tried-and-true business models.

How will this type of consolidation affect the accounting business, and what do firms and their clients need to be on the lookout for as the marketplace evolves?

Assessing the opportunity… and the risk

First and foremost, accounting firm owners need to be aware of just how desirable they are right now. While there has been some buzz in the industry about the growing presence of private equity firms, most of the activity to date has focused on larger, privately held firms. In fact, when we recently asked tax professionals about their exposure to private equity funding in our 2025 State of Tax Professionals Report, we found that just 5% of firms have actually inked a deal and only 11% said they are planning to look, or are currently looking, for a deal with a private equity firm. Another 8% said they are open to discussion. On the one hand, that’s almost a quarter of firms feeling open to private equity investments in some way. But the lion’s share of respondents —  87% — said they were not interested.

Recent private equity deal volume suggests that the holdouts might change their minds when they have a real offer on the table. According to S&P Global, private equity and venture capital-backed deal value in the accounting, auditing and taxation services sector reached more than $6.3 billion in 2024, the highest level since 2015, and the trend shows no signs of slowing. Firm owners would be wise to start watching this trend to see how it might affect their businesses — whether they are interested in selling or not.

Focus on tech and efficiencies of scale

The reason this trend is so important to everyone in the industry right now is that the private equity firms entering this space are not trying to become accountants. They are looking for profitable exits. And they will do that by seizing on a critical inflection point in the industry that’s making it possible to scale accounting firms more rapidly than ever before by leveraging technology to deliver a much wider range of services at a much lower cost. So, whether your firm is interested in partnering with private equity or dead set on going it alone, the hyperscaling that’s happening throughout the industry will affect you one way or another.

Private equity thrives in fragmented businesses where the ability to roll up companies with complementary skill sets and specialized services creates an outsized growth opportunity. Andrew Dodson, managing partner at Parthenon Capital, recently commented after his firm took a stake in the tax and advisory firm Cherry Bekaert, “We think that for firms to thrive, they need to make investments in people and technology, and, obviously, regulatory adherence, to really differentiate themselves in the market. And that’s going to require scale and capital to do it. That’s what gets us excited.”

Over time, this could reshape the industry’s market dynamics by creating the accounting firm equivalent of the Traveling Wilburys — supergroups capable of delivering a wide range of specialized services that smaller, more narrowly focused firms could never previously deliver. It could also put downward pressure on pricing as these larger, platform-style firms start finding economies of scale to deliver services more cost-effectively.

The technology factor

The great equalizer in all of this is technology. Consistently, when I speak to tax professionals actively working in the market today, their top priorities are increased efficiency, growth and talent. Firms recognize they need to streamline workflows and processes through more effective use of technology, and they are investing heavily in AI, automation and data analytics capabilities to do that. Private equity firms, of course, are also investing in tech as they assemble their tax and accounting dream teams, in many cases raising the bar for the industry.

The question is: Can independent firms leverage technology fast enough to keep up with their deep-pocketed competition?

Many firms believe they can, with some even going so far as to publicly declare their independence.  Regardless of the path small to midsized firms take to get there, technology-enabled growth is going to play a key role in the future of the industry. Market dynamics that have been unfolding for the last decade have been accelerated with the introduction of serious investors, and everyone in the industry — large and small — is going to need to up their games to stay competitive.

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Trump tax bill would help the richest, hurt the poorest, CBO says

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The House-passed version of President Donald Trump’s massive tax and spending bill would deliver a financial blow to the poorest Americans but be a boon for higher-income households, according to a new analysis from the Congressional Budget Office.

The bottom 10% of households would lose an average of about $1,600 in resources per year, amounting to a 3.9% cut in their income, according to the analysis released Thursday. Those decreases are largely attributable to cuts in the Medicaid health insurance program and food aid through the Supplemental Nutrition Assistance Program.

Households in the highest 10% of incomes would see an average $12,000 boost in resources, amounting to a 2.3% increase in their incomes. Those increases are mainly attributable to reductions in taxes owed, according to the report from the nonpartisan CBO.

Households in the middle of the income distribution would see an increase in resources of $500 to $1,000, or between 0.5% and 0.8% of their income. 

The projections are based on the version of the tax legislation that House Republicans passed last month, which includes much of Trump’s economic agenda. The bill would extend tax cuts passed under Trump in 2017 otherwise due to expire at the end of the year and create several new tax breaks. It also imposes new changes to the Medicaid and SNAP programs in an effort to cut spending.

Overall, the legislation would add $2.4 trillion to US deficits over the next 10 years, not accounting for dynamic effects, the CBO previously forecast.

The Senate is considering changes to the legislation including efforts by some Republican senators to scale back cuts to Medicaid.

The projected loss of safety-net resources for low-income families come against the backdrop of higher tariffs, which economists have warned would also disproportionately impact lower-income families. While recent inflation data has shown limited impact from the import duties so far, low-income families tend to spend a larger portion of their income on necessities, such as food, so price increases hit them harder.

The House-passed bill requires that able-bodied individuals without dependents document at least 80 hours of “community engagement” a month, including working a job or participating in an educational program to qualify for Medicaid. It also includes increased costs for health care for enrollees, among other provisions.

More older adults also would have to prove they are working to continue to receive SNAP benefits, also known as food stamps. The legislation helps pay for tax cuts by raising the age for which able bodied adults must work to receive benefits to 64, up from 54. Under the current law, some parents with dependent children under age 18 are exempt from work requirements, but the bill lowers the age for the exemption for dependent children to 7 years old. 

The legislation also shifts a portion of the cost for federal food aid onto state governments.

CBO previously estimated that the expanded work requirements on SNAP would reduce participation in the program by roughly 3.2 million people, and more could lose or face a reduction in benefits due to other changes to the program. A separate analysis from the organization found that 7.8 million people would lose health insurance because of the changes to Medicaid.

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