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Strategic Preparation for Form 6765 Updates for Tax Year 2024

DST Advisory Group - Preparation for Form 6765 Updates, 2024

Adapting to Change: Strategic Preparation for Form 6765 Updates for Tax Year 2024


As we venture further into 2024, the impending revisions to Form 6765 loom over businesses aiming to claim Research and Development (R&D) tax credits. These changes, signifying the IRS’s commitment to enhancing claim validity and compliance, introduce a new layer of complexity to an already intricate process. With the clock ticking, the urgency for businesses to align their internal practices with these new requirements cannot be overstated. This article delves into the specifics of the proposed changes, particularly focusing on Sections E and F, and outlines strategic steps for businesses to ensure seamless compliance. By embracing a proactive approach, companies can navigate these changes effectively, safeguarding their R&D tax credit claims against the backdrop of evolving IRS scrutiny.

Section 1: Unpacking the Proposed Changes to Form 6765

The IRS’s initiative to revise Form 6765 underscores a broader objective: to refine the process of claiming R&D tax credits by demanding more detailed information from taxpayers. This move is designed to mitigate the risk of non-compliant claims slipping through the system, ensuring that only legitimate R&D activities are rewarded.

Detailed Examination of Sections E & F

Section E Changes:

The introduction of Section E marks a significant shift towards requiring taxpayers to disclose qualitative details about their R&D efforts. The new questions in this section encompass:

  • Business Components: Taxpayers must now specify the number of business components included in their credit calculation. This change aims to provide the IRS with a clearer understanding of the scope and diversity of R&D activities within a company.
  • Officer’s Wages: The form seeks information on the amount of officer’s wages counted as wages for qualified services, highlighting the IRS’s focus on scrutinizing the direct involvement of high-level personnel in R&D activities.
  • Business Acquisitions or Disposals: Disclosure of any significant business acquisitions or disposals during the tax year is required, reflecting the IRS’s interest in how such transactions impact R&D expenditure claims.
  • New Categories of Expenditures: Perhaps the most ambiguous yet critical addition, this question probes whether new categories of expenditures were included in the current year’s qualified research expenditures (QREs), signaling the IRS’s effort to ensure consistency and accuracy in expenditure reporting.
  • ASC 730 Directive Compliance: The inquiry into whether QREs were determined following the ASC 730 Directive underscores the IRS’s push for standardization in how companies calculate and substantiate their R&D expenses.

Section F Changes:

Section F delves deeper into the specifics of each business component involved in the R&D claim. The detailed requirements include:

  • Component Descriptions: Taxpayers are expected to provide a descriptive name and detailed account of the research objectives for each business component.
  • Experimentation Process: There’s a call for information on the experimentation process, including the alternatives evaluated, which reflects the IRS’s criteria for qualifying R&D activities.
  • New or Improved Designation: Identifying whether a business component is new or improved helps the IRS assess the novelty and advancement of the research.
  • Type and Use of Business Components: This categorization aids in understanding the application and commercialization of the R&D outcomes.

These updates to Sections E and F are more than mere procedural tweaks; they represent a strategic pivot by the IRS towards a more data-driven, substantiated approach to evaluating R&D tax credit claims.

Section 2: Preparing for Compliance in 2024

With the year already underway, the window for businesses to adapt their practices to these new requirements is narrowing. It’s imperative that both technical and financial staff are primed for the changes, ensuring that internal record-keeping and documentation practices are robust and aligned with the IRS’s expectations. Here are some best practices and technological solutions that can facilitate this transition, ensuring businesses remain aligned with the new requirements:

  • Simplifying Documentation and Recordkeeping:
  • Centralize Your Documentation: Encourage your team to store all project-related notes and records in a single, accessible location. Imagine it as a communal library where everyone can easily find what they’re looking for.
  • Emphasize Document Retention: Make sure everyone understands the value of holding onto these records. It’s akin to preserving important memories, ensuring they’re always there when you need to look back on them.
  • Refine Your Recordkeeping Habits: Take some time to assess and enhance how you keep records. It’s about making your documentation process as straightforward and efficient as possible.
  • Document Your Documentation Process: Yes, it sounds a bit meta, but writing down how you document and store information ensures consistency and clarity for everyone involved. Think of it as creating a recipe that everyone in your team can follow to bake the perfect documentation pie.
  • Integration of Cross-Functional Teams:
    • Regular Collaboration Meetings: Facilitate ongoing dialogue between R&D, tax, and finance teams to ensure a unified approach to identifying and documenting QRAs and QREs.
    • Shared Documentation Platforms: Implement cloud-based storage solutions where all relevant documentation can be accessed and updated by team members in real-time.
  • Proactive Training and Education:
    • Internal Workshops: Conduct workshops or training sessions focused on the changes to Form 6765 and their implications for your organization’s R&D tax credit claims.
    • External Consultations: Engage with tax advisors or consultants who specialize in R&D tax credits for insights on aligning with the new form requirements.
  • Strategic Review of R&D Activities:
    • Assessment of Business Components: Regularly review and assess all R&D activities to ensure they meet the IRS’s updated definitions and requirements for qualifying research.
    • Documentation of New Expenditure Categories: Specifically identify and document any new categories of expenditures introduced in the current tax year, providing clear rationales for their inclusion.
  • Technological Considerations:
    • Incorporating technology into your compliance strategy not only streamlines the process but also enhances the accuracy and integrity of your R&D tax credit claims. From project management tools that facilitate detailed record-keeping to specialized tax software that aligns with IRS requirements, technology can be a game-changer in adapting to the new landscape.

Section 3: Leveraging DST’s Expertise

In navigating the complexities introduced by the updates to Form 6765, DST’s unique three-pronged approach offers a strategic advantage. Combining the technical acumen of tax engineers with the analytical prowess of tax associates and the precision of case law review, DST is poised to guide companies through the compliance maze with unparalleled expertise.

Role of Tax Engineers

DST’s Tax Engineers play a pivotal role in this approach, acting as the bridge between a company’s operational team and its strategic tax planning efforts. Their deep understanding of both the technical nuances of R&D activities and the intricacies of tax law enables them to identify, document, and substantiate QRAs effectively. This collaboration is critical in ensuring that every aspect of R&D tax credit claims is robust, compliant, and optimized for the IRS’s scrutiny.

Preparing with DST

Engaging with DST not only prepares companies for the immediate challenges posed by the new Form 6765 requirements but also positions them strategically for future tax planning. DST’s methodology, honed through years of experience and success in navigating IRS expectations, offers companies peace of mind and strategic advantage in their R&D tax credit endeavors.

What’s Next? Anticipating the Final Version of Form 6765

As we await the IRS’s release of the final version of Form 6765, it’s important to note that the form underwent industry consultation last fall. Feedback from this consultation is being considered, and while there may be minor adjustments to address certain disconnects between claimants’ studies and the information requirements, the core structure and intent of the form are expected to remain consistent. The anticipation is that the form will not materially change from its current iteration to its final version.

This understanding is crucial for companies as they prepare their internal processes for compliance. The proposed changes, particularly in Sections E and F, are indicative of the IRS’s direction and its commitment to tightening the review process for R&D tax credit claims. Companies should proceed with their preparations under the assumption that these changes will be largely upheld in the final version of the form.

In this landscape of anticipation and preparation, the emphasis on detailed, contemporaneous documentation, and the integration of technical and financial perspectives remain paramount. Businesses are advised to continue refining their internal record-keeping practices, ensuring they are well-positioned to meet the new requirements head-on.


The revisions to Form 6765 represent a significant shift in the IRS’s approach to R&D tax credit claims, emphasizing the need for detailed, substantiated information. Preparing for the changes to Form 6765 involves a holistic approach that combines best practices in documentation and collaboration with strategic use of technology. By adopting these practices and considering the integration of specialized software solutions, companies can enhance their compliance posture, ensuring that their R&D tax credit claims are robust, substantiated, and aligned with the IRS’s evolving requirements. Engaging with experts like DST can provide the additional insights and support needed to navigate this transition smoothly, leveraging both human expertise and technological advancements to secure your R&D tax benefits.

Further reading: Statistical Sampling Success: Adapting Your R&D Tax Credit Study Approach for the New IRS Rules