IRS Extends Feedback Period for Form 6765: What Taxpayers Need to Know About Section G

Executive Summary

• The IRS has made the newly introduced Section G of Form 6765 optional for the 2025 tax year (filing in 2026). This section, which requires a granular breakdown of qualified research expenses—including specific business components, wages, and supplies—will not become mandatory until the 2026 tax year, giving businesses additional time to align their internal documentation processes.

• The comment period for the draft instructions has been extended to March 31, 2026, and the “perfecting” period for research credit refund claims is now extended through January 10, 2027. This transition period is particularly beneficial for R&D-heavy firms, as it allows for a 45-day window to correct administrative errors in refund claims before they are finalized.

The IRS has announced an important update for businesses claiming the Credit for Increasing Research Activities—commonly known as the research credit. In response to stakeholder feedback, the agency is making Section G of Form 6765 optional for tax year 2025 and extending the comment period for the draft instructions.

What Is Section G?

Section G is a newly introduced part of Form 6765 that requires detailed reporting on qualified research activities for related business components. This includes:

• Identifying each business component;
• Describing the research activities performed; and
• Breakdown of qualified expenses (wages, supplies, computer hosting, and contract research).

The goal is to improve transparency and consistency in how taxpayers substantiate their research credit claims.

Key Updates from the IRS Announcement

Here are the major takeaways from the IRS’s October 1, 2025 news release:

• Section G will remain optional for all filers for tax year 2025 (processing year 2026).
• Mandatory reporting begins in tax year 2026, with exceptions for:
  • Qualified Small Businesses claiming a reduced payroll tax credit.
  • Taxpayers with QREs ≤ $1.5 million and gross receipts ≤ $50 million who claim the credit on an original return.
• The IRS has extended the comment period for the draft instructions through March 31, 2026.
• The transition period for research credit refund claims—which allows taxpayers 45 days to perfect a claim—has been extended through January 10, 2027.

Why This Matters

For R&D-heavy businesses, this extension offers more time to prepare for the new reporting requirements and to provide feedback that could shape the final version of the form. It also reflects the IRS’s commitment to balancing compliance with administrative burden.

How to Submit Feedback

Taxpayers and stakeholders can email their comments to lbi.rt.team@irs.gov with the subject line: “Instructions for Form 6765”.

Looking Ahead

The IRS plans to release revised instructions in January 2026, giving businesses time to adapt before Section G becomes mandatory. In the meantime, companies should begin reviewing their internal documentation processes to ensure they can meet the new standards when required. If you have questions about the information outlined above call 801-532-7444 or click here to contact us. We look forward to speaking with you soon.