Understanding the IRS Extension on Form 6765 Feedback and Its Benefits for Taxpayers and CPAs
- AndreTaxCo
- Oct 10
- 5 min read
The IRS recently announced (IR-2025-99, Oct. 1, 2025) an extension for feedback on Form 6765, Credit for Increasing Research Activities, which is essential for claiming the Research and Development (R&D) Tax Credit under IRC § 41 and its accompanying draft instructions.¹ This extension means taxpayers and tax professionals have a unique chance to communicate with the IRS about the usability and clarity of the form. The IRS has decided to extend the comment period for the draft instructions through March 31, 2026, to alleviate taxpayer burden and in the interest of fair and effective tax administration.
Section G of Form 6765 will be optional for all filers for tax year 2025 (processing year 2026).
For tax year 2026 (processing year 2027) and beyond, Section G will be mandatory for all filers with optional reporting for:
Qualified small business (QSB) taxpayers, defined in section 41(h)(3) of the Internal Revenue Code who check the box to claim a reduced payroll tax credit; or
Taxpayers with total qualified research expenses (QREs) equal to or less than $1.5 million, determined at the control group level and equal to or less than $50 million of gross receipts, as determined under section 448(c)(3) (without regard to subparagraph (A) thereof), claiming a research credit on an original filed return.
The IRS also is extending the research credit claim transition period, which gives taxpayers 45 days to perfect a research credit claim for refund prior to IRS’s final determination on the claim, through January 10, 2027.²
To submit a claim for refund for the research credit postmarked after June 18, 2024, that is sufficient for the IRS to consider taxpayers must:
Identify all the business components to which the Section 41 research credit claim relates for that year,
Identify all research activities performed for each business component, and
Provide the total qualified employee wage expenses, total qualified supply expenses, and total qualified contract research expenses for the claim year.³ Taxpayers may use Form 6765, Credit for Increasing Research Activities for this purpose.
In this post, we will look into why this extension is significant, what benefits it provides, and how it can improve the experience of claiming R&D tax credits.
Why the Delay Matters: Strategic Opportunity for R&D Tax Planning
From a technical standpoint, this extension offers a rare window for both taxpayers and practitioners to prepare for the new mandatory reporting regime while proactively aligning their § 174 and § 41 analyses.
By extending the feedback period on Form 6765, the IRS shows its commitment to improving the form's clarity and functionality. More time for input allows for enhancements that must make the process of claiming R&D tax credits easier and more efficient for everyone involved.
Strengthened Compliance Readiness
The extension enables taxpayers to conduct a full internal review of their R&D tracking and cost-accounting systems. Firms can evaluate how their data capture aligns with the IRS’s anticipated disclosure requirements under Section G—particularly the identification of business components, wage and contract allocations, and project documentation.
Documentation and Audit Defense Enhancement
Given recent IRS scrutiny over R&D credit substantiation, taxpayers should treat this period as an opportunity to update their study methodologies, documentation templates, and internal controls. A contemporaneous, project-based analysis will not only ease the eventual Section G transition but also fortify audit defense under §§ 41(d) and 6001.
Opportunity for Practitioner Input
The IRS’s extended comment period allows CPAs, enrolled agents, and tax attorneys to influence the final design of Form 6765. Professionals can highlight recurring compliance challenges—such as software development cost classification, contract research allocation, and overlap between § 174A expensing and § 41 credit eligibility—before the rules become mandatory.
Enhanced Taxpayer Awareness and Claim Optimization
Historically, many qualified businesses overlook the R&D credit. In tax year 2013, for example, over 42,000 corporations claimed credits exceeding $6 billion, illustrating broad participation and financial significance.⁴ With modern incentives under the One Big Beautiful Bill Act of 2025 (OBBBA) introducing § 174A expensing elections, accurate and complete Form 6765 reporting becomes even more critical for maximizing credit value.
Benefits for Taxpayers
The extension of the feedback period on Form 6765 brings several benefits specifically for taxpayers.
Greater Clarity
With the chance to give feedback, taxpayers can help the IRS pinpoint confusing elements within the form. This collaboration can lead to clearer instructions and guidelines. For example, a comment could suggest clearly labeling expenses related to software development, which is often misunderstood.
Increased Confidence
As taxpayers participate in this feedback process, they may become more confident in handling the R&D tax credit process. Knowing their input matters can empower businesses to take steps they might have ignored before. Confidence can lead to a higher claim success rate, which is crucial for financial recovery.
Potential for Higher Credits
Improving the clarity and usability of Form 6765 can enable taxpayers to claim higher R&D tax credits. A better understanding of the requirements can result in more accurate claims. According to IRS data, eligible companies could receive credits that cover up to 20% of qualified research expenses, a significant financial incentive.
Benefits for Tax Filing Consultants
Tax filing consultants, such as CPAs and tax attorneys, also benefit from the IRS's extension on feedback for Form 6765.
Enhanced Client Support
With this feedback opportunity, tax professionals can better assist their clients through the R&D tax credit process. A clearer form means consultants can give tailored advice, ensuring clients maximize their potential credits. For example, a consultant might recommend specific software tools that help track research expenses, enhancing overall documentation.
Improved Documentation Practices
Consultants can use this feedback period to advocate for better practices related to R&D tax reporting. By advocating for clearer documentation guidelines, tax professionals can help their clients effectively substantiate claims. This not only strengthens their client relationships but also enhances the overall credibility of R&D claims.
Strengthened Professional Relationships
This collaboration with the IRS can strengthen relationships between tax professionals and the agency. By actively participating in enhancements to Form 6765, consultants can position themselves as trusted advisors engaged in shaping tax policy and practices.
Final Thoughts
he IRS’s decision to extend both the Form 6765 feedback period and the § 41 refund-claim transition window represents a significant and practical benefit for the tax community. Taxpayers and practitioners should leverage this period to refine documentation practices, integrate § 174/§ 41 data workflows, and ensure that future R&D credit filings are defensible, efficient, and audit-ready.
Citations:
Internal Revenue Serv., IRS Announces Extension of Comment Period for Form 6765, Credit for Increasing Research Activities, and Draft Instructions (IR-2025-99, Oct. 1, 2025), https://www.irs.gov/newsroom/.
Internal Revenue Serv., Additional Time to Perfect Research Credit Refund Claims Extended Through Jan. 10, 2027 (2025), https://www.irs.gov/newsroom/.
See id.; see also Chief Counsel Memorandum 20214101F (Oct. 15, 2021) (outlining documentation requirements for § 41 refund claims).
Internal Revenue Serv., Statistics of Income—Corporation Research Credit, Tax Year 2013 (rev. 2019), https://www.irs.gov/statistics/soi-tax-stats-corporation-research-credit.
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