
In this 3-part series, Mark Dunning and Jamie Overberg of TaxOps will lead tax professionals, advisors, and in-house teams through the latest updates, compliance requirements, and audit risks tied to Section 174 and the IRS’s evolving R&D tax credit expectations.
U.S. Business Innovation and R&D Tax Credits
CPE 3-part Series
Bundle pricing available at COCPA
Major legislative changes are shaking up the R&D tax credit landscape—again. This 3-part series brings together top experts from TaxOps to help tax professionals, advisors, and in-house teams navigate the latest updates, compliance requirements, and audit risks tied to Section 174 and the IRS’s evolving expectations.
From the game-changing One Big Beautiful Bill Act to the revamped Form 6765 and enhanced audit scrutiny, each session is packed with practical insights to help you protect your clients, prepare your filings, and confidently claim credits in this new era.
Session 1: Section 174 and the One Big Beautiful Bill Act: What It Means for Businesses CPE
September 24 | 12:00 – 12:50 pm MDT
Understand the sweeping changes introduced by the OBBB Act, including the return of immediate expensing for domestic R&D. Explore the new Section 174A, retroactive relief, and what’s next from the IRS.
In a landmark move for U.S. innovation, the One Big Beautiful Bill Act (OBBBA)—signed into law on July 4, 2025—restored immediate deductions for domestic R&D expenditures, reversing a key provision of the 2017 Tax Cuts and Jobs Act. This first session in our 3-part series unpacks what this means for businesses and how to take advantage of the new rules.
Join Mark Dunning, partner at TaxOps, as he explores the new Section 174A, return to immediate expensing, and foreign R&D rules. We’ll also cover election flexibility, retroactive relief for small businesses, and accelerated deductions as well as discuss IRS guidance Rev. Proc. 2025-28. Whether you’re a tax practitioner or in-house, this session will help you navigate the new R&D tax landscape with confidence.
Learning Objectives
- Identify the key provisions of Section 174A and determine their impact on domestic R&D activities beginning in 2025.
- Compare the tax treatment of domestic versus foreign R&D expenditures under the reinstated expensing rules.
- Evaluate election options for expensing or capitalizing R&D costs and apply automatic method change procedures.
- Assess eligibility for retroactive small business provision relief and outline the process for amending prior-year returns.
- Prepare for potential future guidance related to R&D tax credits.
Major Topics
- Section 174A and the return of immediate R&D expensing
- Differentiation between domestic and foreign R&D tax treatment
- R&D expensing elections and automatic accounting method changes
- Retroactive relief for small businesses and amended return procedures
- Anticipated IRS guidance and future implications for R&D credits
Session 2: Preparing Revised Form 6765 for R&D Credit Compliance CPE
October 30 | 8:30 – 9:20 am MDT
Get up to speed on the IRS’s expanded Form 6765. Learn how to meet new documentation requirements, avoid common pitfalls, and defend your claims with confidence.
The IRS has significantly revised Form 6765, Credit for Increasing Research Activities, introducing new sections and expanded reporting requirements aimed at increasing transparency and curbing questionable claims. These changes—some effective in 2024 and others mandatory in 2025—have major implications for how businesses calculate and substantiate their R&D tax credits.
In this second installment of our 3-part series, Jamie Overberg, Partner at TaxOps Minimization, will walk you through the updated form, explain how to meet the new documentation standards, and share strategies for defending your credit claims under heightened IRS scrutiny. Whether you’re a seasoned tax professional or advising clients new to the R&D credit, this session will equip you with the tools to navigate the evolving landscape with confidence.
Learning Objectives
- Summarize the purpose of Form 6765 and its role in claiming the federal R&D tax credit.
- Analyze the new reporting requirements introduced in Sections E, F, and G of Form 6765.
- Compare the regular and alternative simplified credit methods and determine their applicability to specific taxpayer scenarios.
- Apply the rules for offsetting payroll tax liabilities with the R&D credit using Form 8974.
- Implement best practices for documentation, compliance, and audit readiness in response to increased IRS scrutiny.
Major Topics
- Overview and purpose of IRS Form 6765
- 2024–2025 changes to Sections E, F, and G of Form 6765
- Regular vs. alternative simplified credit calculations
- Use of Form 8974 to apply R&D credit to payroll taxes
Session 3: Audit Readiness: An IRS Primer for R&D Credit Compliance CPE
December 4 | 8:30 – 9:20 am MDT
Discover how to build a defensible audit trail with strong documentation and cross-functional collaboration. Explore what the IRS really wants—and how to deliver it.
Audit readiness is not optional when it comes to R&D credits—it’s essential. In this final session of our 3-part series, we’ll focus on the IRS’s evolving expectations around nexus, business component documentation, and contemporaneous recordkeeping. With expanded reporting requirements now in effect, businesses must implement more rigorous tracking and documentation processes to support their claims and withstand IRS review.
Mark Dunning, Partner at TaxOps, Mark Dunning, partner at TaxOps, will break down what the IRS is really asking for when it comes to business components by activity and how to build a defensible audit trail through contemporaneous documentation. This session will also explore the role of cross-functional collaboration—especially with engineering and accounting teams—in identifying gaps, improving data quality, and reducing audit risk. Whether you’ve already received an IRS notice or want to stay ahead of compliance challenges, this webinar will equip you with practical strategies to protect your R&D credit claims.
Learning Objectives
- Interpret IRS expectations for documenting business components by activity to establish proper nexus for R&D credit claims.
- Develop a defensible audit trail using contemporaneous documentation practices aligned with IRS standards.
- Identify red flags in third-party R&D credit methodologies and evaluate associated compliance risks.
- Formulate appropriate responses to IRS notices involving uncertain tax positions.
- Implement strategies to mitigate Section 174 capitalization impacts and coordinate internal teams for audit readiness.
Major Topics
- IRS expectations for nexus and business component documentation
- Contemporaneous recordkeeping and audit trail best practices
- Risk evaluation of aggressive credit methodologies
- Response strategies for IRS correspondence and tax position disclosures
- Section 174 capitalization planning and cross-functional compliance coordination
Presenters
Mark Dunning, Partner, TaxOps,
Jamie Overberg, Partner, TaxOps Minimization
Read more
- Auditor Independence in the Age of Private Equity: What CFOs Need to Know
- R&D Credits for Software Companies: Scrum Teams, Qualifiers, and Section 174 After OBBBA
- Section 174 Decoupling: What Tax Pros Need To Know State By State
- TaxOps Welcomes Sean Espy as Partner, Tax Minimization
- Your Tax Footprint Is Probably Bigger Than You Think: What Finance Leaders Need to Know About State Nexus
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