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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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Tariffs collide with taxes in Trump bill

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The tax reconciliation bill making its way through Congress is expected to add trillions of dollars to the national debt, but the Trump administration hopes to offset the cost through income from tariffs. Accountants are helping worried companies deal with the possible fallout.

“Obviously, tariffs create a lot of uncertainty,” said Tom Alongi, a partner and U.S. national manufacturing practice leader at UHY, a Top 50 Firm based in Farmington Hills, Michigan. “But with uncertainty for U.S. manufacturers, it creates a lot of opportunity. And for those that are contract manufacturers that use a lot of offshoring, it creates a tremendous amount of angst, especially among the auto industry that really over the last three decades has turned into a global supply chain as we’ve been in a race to the bottom to reduce costs.”

UHY has been helping CFOs deal with the changing tariff policies coming out of the White House. “A lot of companies don’t even realize how deep some of their supply chain and where some of their raw material and purchased components ultimately originate,” said Alongi. 

That involves quantifying the impact, understanding the origin of components and raw materials, and where that fits in the Harmonized System that’s administered by the International Trade Administration, making sure everything is classified correctly. 

The Trump administration hopes to convince more companies to relocate their manufacturing operations to the U.S. But companies are also looking at changing their sourcing to other countries if they’ve been relying too heavily on Chinese-made supplies amid the ever-changing tariff pronouncements.

“That uncertainty does create challenges within our clients of allocation of capital,” said Alongi. “Do I make big bets to transition if I have a huge amount of risk that is isolated in a certain country? What do we potentially do to mitigate that risk?”

Auto manufacturers need to look at the proposed changes to tax credits in the tax bill, including reductions in electric vehicle tax credits and other tax incentives for renewable energy.

“I always knew that it is a great alternative source that fits certain consumers, but I never believed that it was going to take over the world,” said Alongi, who has been driving an EV for over seven years. “The tax credits create a behavior, and they incentivize people to drive electric.” 

The shortcomings in the national infrastructure for charging EV batteries disincentivize broader takeup, and the disappearance of the tax credits would make the vehicles even less affordable.

CBIZ, a Top 10 Firm based in Cleveland, launched an Integrated Tariff Solutions program earlier this month for its clients nationwide, offering support across finance, operations, supply chain strategy, tax and compliance. 

“Like so many other middle-market companies, certainly the larger companies, in this environment, there’s more demand for advice on mitigating exposure,” said Mark Baran, managing director of CBIZ’s National Tax Office. “Tariffs have been relatively low for a long time, and now the supply chain, pricing, vendor relationships and locations of where goods are manufactured need a fresh look.”

Different industries are looking for help, including manufacturing, construction and import. “They’re really looking at how to mitigate these costs, which don’t appear to be slowing down,” said Baran. “It could be temporary, but it’s not right now. So we have developed a number of different avenues to assist our clients, whether it’s evaluating inventory and how to properly account for inventory, whether it’s seeking to help them find locations in the U.S. if they want to bring their manufacturing back to the U.S. and do that in a tax efficient manner. We’re looking at intercompany transactions and layering transfer pricing concepts onto customs, seeing if we could help with savings in that regard. Depending upon what a client does and their structure, there’s probably a number of ways you can tackle tariffs and get ahead of it. “

Customs valuations are important. “It’s really ensuring that you have an accurate customs valuation, and oftentimes that wasn’t looked at accurately, and there are savings that can result from that,” said Baran. “These are considered an intercompany framework, oftentimes on the businesses that are most impacted by this. Looking at that structure is another way of doing this, not just not just transfer pricing, but location-based analysis. It’s taking what has been decades of international tax knowledge and layering on customs, and that’s providing a framework that’s been tested and works and is valuable.”

Baran has also been keeping a close eye on developments with the overall tax legislation. House Republicans have come under pressure from President Trump to finalize the bill this week, but that won’t be the end of the story. “What’s waiting for them at the Senate tells me that this bill may not look the same because there’s already opposition from the Senate, and the Senate has a lot of rules that they need to follow,” said Baran. “The Senate has concerns, and the Senate instructions in the budget reconciliation concurrent resolution are very different than the House, so you may have a House and a Senate that’s producing two completely different bills. While it’s nice to report and discuss all of the changes that are coming out of the House, I think people should just keep in mind that the Senate is next, and do not assume that they will follow suit. So the ultimate bill that’s eventually produced is going to look a lot different than it does now.”

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Fastest-growing accounting firms spend double on marketing

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The fastest-growing accounting firms spend twice as much on their marketing budget than all other firms, according to a new study.

The Association for Accounting Marketing, in collaboration with the Hinge Research Institute, surveyed over 87 firms — representing 1,037 offices and 66,000 employees — about the drivers behind the marketing performance of the fastest-growing firms. 

High-growth firms invest two-thirds more in employer branding and recruiting, and they budget more for conferences and events, the data found. 

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When it comes to marketing budgets, the fastest-growing firms spent 2.1% of their revenue versus low-growth firms, which spent 1%. Some of that money is invested in marketing teams. High-growth firms have a higher ratio of marketing staff to full-time equivalents (1:49) compared to other firms (1:57). However, the average salary of a high-growth firm team member is 27% less than at the slowest-growing firms. 

“When it comes to marketing, the accounting industry tends to be risk averse and invests less than most other professional services industries,” Liz Harr, managing partner at Hinge, said in a statement. “But the data shows that those that spend more on marketing are getting superior results.”

High-growth firms also spend 66% more on recruiting talent and developing their employer brands — the reputation, culture, employee experiences and marketing that entices potential hires to choose their firm over another — than low-growth firms. 

(Read more: “The 2025 Fastest-Growing Firms”)

Finally, the fastest-growing firms spend 21% more of their marketing budget on conferences and other in-person events than their peers, with high-growth firms allocating 30% of their budget versus low-growth firms allocating 25%. 

“Today’s high-performing accounting firms are taking a somewhat more balanced approach to marketing,” AAM president Laura Metz said in a statement. “Digital and content marketing budgets are on the rise, but perhaps more than anything, high-growth firms are focused on nurturing relationships in person, whether at industry conferences or their own client appreciation events. These gatherings aren’t just line items, they’re growth strategies where the strongest connections, best leads and boldest brand moments take shape.”

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Trump says tax bill ‘close’ as holdouts threaten to sink it

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President Donald Trump said his massive tax package is close to being finalized, having notched a deal over the state and local tax deduction, but the White House has yet to win over a faction of conservatives who want more austere spending cuts.

“We’re doing very well. It’s very close,” Trump told reporters Wednesday.

House Speaker Mike Johnson announced Wednesday that he had an agreement with lawmakers from high-tax states to increase the limit on the SALT deduction to $40,000. 

“The members of the SALT caucus negotiated yesterday in good faith,” Representative Mike Lawler, a New York Republican, told Bloomberg Television. “We settled on something that we believe in, we support.”

However, several hardline Republicans said House GOP leaders aren’t honoring concessions the White House promised them and are threatening to tank the bill. 

But the White House says they never made a deal, instead presenting some of the conservative holdouts with a menu of policy options that the Trump administration can live with, a White House official said. 

The White House made clear to conservatives they would have to persuade their moderate colleagues to sign onto those ideas, the official said, a challenging feat given Republicans’ narrow and fractious House majority.

Trump and Johnson plan to meet with some of the ultraconservative lawmakers at the White House at 3 p.m., a person familiar with the plans said. That meeting will be an opportunity to strike a deal, the Trump official said.

Ultraconservative Representative Andy Harris of Maryland cast the conversations with the White House as a “midnight deal” for deeper cuts in Medicaid and faster elimination of Biden-era clean energy tax breaks.

“I’m sorry, but that’s a pay grade above the speaker,” Harris said. 

Harris said the bill doesn’t reflect that agreement and hardliners will block the package if it comes to a vote. Representative Ralph Norman, an ultraconservative from South Carolina, said the bill “doesn’t have the votes. It’s not even close.”

Freedom Caucus members said they aren’t moving the goal posts by asking for more spending cuts than the budget outline they already voted for. They said they want to rearrange the spending cuts to focus on ending “abuse” in Medicaid and immediately ending green energy tax breaks.

House Republicans leaders are also planning to accelerate new Medicaid work requirements to December 2026 from 2029 in a bid to satisfy ultraconservatives, according to a lawmaker familiar with the discussions. 

How deeply to cut safety-net programs such as food assistance and Medicaid health coverage for the poor and disabled has been a sticking point in reaching agreement on Trump’s tax bill, as Johnson attempts to navigate a narrow and fractious majority.

Harris and Norman spoke shortly after Johnson announced the SALT agreement on CNN. 

Johnson said there is “a chance” the package could come to a vote Wednesday.

But several ultraconservatives cast doubt on that. “There’s a long way to go,” said Representative Chip Roy of Texas, another Republican hardliner.

The speaker can only lose a handful of votes and still pass the bill, which is the centerpiece of Trump’s legislative agenda.

The $40,000 SALT limit would phase out for annual incomes greater than $500,000 for the 10-year length of the bill, Lawler said. The income phaseout threshold would grow 1% a year over a decade, a person familiar with the matter said.

The cap is the same for both individual taxpayers and married couples filing jointly, the person added.

Another person described the income phase-out as gradual, so that taxpayers earning more than $500,000 would not be punished.

Several lawmakers —  New York’s Lawler, Nick LaLota, Andrew Garbarino and Elise Stefanik; New Jersey’s Tom Kean, and Young Kim of California — have threatened to reject any tax package that does not raise the SALT cap sufficiently.

The current write-off is capped at $10,000, a limit imposed in Trump’s first-term tax cut bill. Previously, there was no limit on the SALT deduction and the deduction would again be uncapped if Trump’s first-term tax law is allowed to expire at the end of this year.

Johnson’s plan expands upon the $30,000 cap for individuals and couples included in the initial version of the tax bill released last week. That draft called for phasing down the deduction for those earning $400,000 or more. That plan was quickly rejected by several lawmakers from high-tax districts who called the plan insultingly low.

The acceleration of new Medicaid work requirements could become an issue in the midterm elections — which fall just one month earlier — with Democrats eager to criticize Republicans for restricting health benefits for low-income households. 

House leaders’ initial version of legislation pushed back the new requirements until after the next presidential election.

The earlier date for the Medicaid work requirement could alienate several Republicans from swing districts concerned about cuts to the healthcare program. It is also likely to provoke a backlash in the Senate.

It will be very difficult for states to implement the work requirements in a year and a half, said Matt Salo, a consultant who advises health care companies and formerly worked for the National Association of Medicaid Directors.

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