The IRS has given businesses more time to prepare for changes to Form 6765, Credit for Increased Research Activities. On Oct. 1, 2025, the IRS announced that Section G — an expanded reporting section — will remain optional for all filers for tax year 2025 (processing in 2026).
Here’s what life sciences companies need to know and how to stay ahead.
Understanding Form 6765 Section G
Section G was first introduced as optional for tax year 2024. It asks for more detailed information about your company’s research activities, specifically related to “business components” or developing new or improved products and processes.
Originally, Section G was set to be mandatory for all businesses beginning in tax year 2025. However, after receiving feedback from external shareholders asking for more time to share feedback, the IRS has decided to delay that change. Now, all taxpayers can continue skipping Section G for tax year 2025 while the IRS continues to compile additional commentary for the draft instructions through March 31, 2026.
In the interim, the IRS is expected to release revised Form 6765 instructions for all filers for tax year 2025 in January 2026. The IRS has indicated that feedback about the Form 6755 Instructions may be submitted to [email protected], using the subject line: “Instructions for Form 6765.”
What This Means for Life Sciences Companies
For many in the life sciences industry, this delay will have positive impacts. If your organization wasn’t ready for the expanded reporting, especially the requirements around documenting “business components,” you now have extra time to prepare and ensure compliance.
Section G will eventually increase client and preparer responsibilities, which could restrict future research and experimentation (R&E) credit due to expanded informational reporting requirements and the potential for increased scrutiny of credit claims.
Looking Ahead to Future Tax Years
For tax year 2026 (processing year 2027) and beyond, Section G will be mandatory for all filers with optional reporting for:
- Qualified small business taxpayers, defined in IRC Section 41(h)(3), who check the box to claim a reduced payroll tax credit; and
- Taxpayers with total qualified research expenses equal to or less than $1.5M, determined at the controlled group level, and less than or equal to $50M of gross receipts, as determined under IRC Section 448(c)(3) (without regard to subparagraph (A) thereof), claiming a research credit on an original filed return.
Stay Agile Amid Reporting Shifts With CBIZ
Staying ahead of these new reporting requirements is critical for life sciences companies hoping to maximize research credits and avoid delays or denials. As of now, state R&D credit rules aren’t affected by these federal changes.
If you have questions about the expanded reporting requirements or what this IRS delay means for your business, connect with the CBIZ National Tax Office at [email protected]. We’re here to help you navigate what comes next.
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