[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"doc-seo-302636-105":3,"detail-sidebar-cat-1-en-105":80,"doc-detail-302636-en":126},{"code":4,"msg":5,"data":6},0,"ok",{"site_id":7,"language":8,"slug":9,"title":10,"keywords":11,"description":12,"schema_data":13,"social_meta":73,"head_meta":75,"extra_data":77,"updated_unix":79},105,"en","nam-comment-letter-proposed-changes-to-form-6765-credit-for-increasing-research-activities","NAM Comment Letter - Proposed Changes to Form 6765, Credit for Increasing Research Activities","","October 31, 2023 letter from the National Association of Manufacturers to IRS officials regarding proposed changes to Form 6765, Credit for Increasing Research Activities, announced in IR-2023-173. The letter argues the new R&D tax credit reporting requirements would substantially raise compliance burdens, frustrate claims—especially for small manufacturers—and threaten innovation and high-paying jobs supported by R&D spending. It also outlines the four-part statutory test governing eligibility, requests withdrawal of the proposed changes, and proposes simplifications and delaying the 2024 effective date by at least one year.",{"@graph":14,"@context":72},[15,34,55],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/template/","Template",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/template/letters/","Letters",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/template/nam-comment-letter-proposed-changes-to-form-6765-credit-for-increasing-research-activities/302636/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/nam-comment-letter-proposed-changes-to-form-6765-credit-for-increasing-research-activities/302636.png","ImageObject",442,249,{"name":42,"@type":43},"Guten tag","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-09-26","2026-09-19",true,{"@type":52,"interactionType":53,"userInteractionCount":22},"InteractionCounter",{"@type":54},"ViewAction",{"@type":56,"mainEntity":57},"FAQPage",[58,64,68],{"name":59,"@type":60,"acceptedAnswer":61},"Why does NAM oppose the proposed changes to Form 6765?","Question",{"text":62,"@type":63},"NAM says the proposed new reporting requirements would impose extraordinary compliance costs, frustrate taxpayers’ ability to claim the credit (especially small manufacturers), and thereby threaten innovation and high-paying jobs.","Answer",{"name":65,"@type":60,"acceptedAnswer":66},"What is the four-part test used to determine R&D tax credit eligibility?",{"text":67,"@type":63},"The test requires that expenditures are specified research expenses under Section 174, activities are technological in nature, they are intended to be useful in developing a new or improved business component, and substantially all activities constitute elements of a process of experimentation.",{"name":69,"@type":60,"acceptedAnswer":70},"What does NAM request if the IRS does not withdraw the changes?",{"text":71,"@type":63},"NAM requests withdrawal; if not withdrawn, it suggests modifications and clarifications to simplify claiming compliance and to delay the proposed 2024 effective date by at least one year.","https://schema.org",{"og:url":32,"og:type":74,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":76,"canonical":32},"index,follow",{"doc_id":78,"site_id":7},302636,1790459411,{"code":4,"msg":81,"data":82},"success",[83,88,93,98,103,108,113,117,122],{"id":84,"doc_module":22,"doc_module_name":25,"category_name":85,"show_sort_weight":86,"slug":87},11,"Presentations",90,"presentations",{"id":89,"doc_module":22,"doc_module_name":25,"category_name":90,"show_sort_weight":91,"slug":92},12,"Resumes",80,"resumes",{"id":94,"doc_module":22,"doc_module_name":25,"category_name":95,"show_sort_weight":96,"slug":97},14,"Invoices",70,"invoices",{"id":99,"doc_module":22,"doc_module_name":25,"category_name":100,"show_sort_weight":101,"slug":102},15,"Posters",60,"posters",{"id":104,"doc_module":22,"doc_module_name":25,"category_name":105,"show_sort_weight":106,"slug":107},16,"Social Media",50,"social-media",{"id":109,"doc_module":22,"doc_module_name":25,"category_name":110,"show_sort_weight":111,"slug":112},17,"Forms",40,"forms",{"id":114,"doc_module":22,"doc_module_name":25,"category_name":29,"show_sort_weight":115,"slug":116},18,30,"letters",{"id":118,"doc_module":22,"doc_module_name":25,"category_name":119,"show_sort_weight":120,"slug":121},21,"Paper Templates",5,"papers-templates",{"id":123,"doc_module":22,"doc_module_name":25,"category_name":124,"show_sort_weight":4,"slug":125},158,"General","general-158",{"code":4,"msg":81,"data":127},{"doc_id":78,"user_id":128,"nickname":42,"user_avatar":129,"doc_module":22,"category_id":114,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":26,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":135,"language":136,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":12,"update_tm":140,"read_time":26},687212321768,"https://ap-avatar.wpscdn.com/avatar/a0010bdbe886d2fe77?x-image-process=image/resize,m_fixed,w_180,h_180&k=1789897067658708522","October 31 , 2023  \nMs. Holly Paz  \nCommissioner  \nLarge Business & International Division Internal revenue Service  \n1111 Constitution Ave. NW Washington, DC 20224  \nMs. Jennifer Best  \nDeputy Commissioner  \nLarge Business & International Division Internal Revenue Service  \n1111 Constitution Ave. NW Washington, DC 20224  \nRe: Proposed Changes to Form 6765, Credit for Increasing Research Activities  \nDear Ms. Paz and Ms. Best:  \nThe National Association of Manufacturers respectfully submits this letter in response to proposed changes for Form 6765, Credit for Increasing Research Activities, announced by the IRS in IR-2023-173 on September 15, 2023.1  \nThe NAM is the largest manufacturing association in the United States, representing manufacturers of all sizes in every industrial sector and all 50 states. Manufacturing employs more than 13 million men and women who make things in America, contributes more than $2.91 trillion to the U.S. economy annually , pays workers over 18% more than the average for all businesses and has one of the largest sectoral multipliers in the economy.  \nDriving more innovation than other sectors, research and development is the lifeblood of manufacturing. Manufacturers perform 53% of all private-sector R&D. The industry’s ability to pursue first-in-the-world research would be seriously threatened by the unprecedented proposed new reporting requirements for the R&D tax credit which would impose extraordinary compliance costs on taxpayers. In other words, these new requirements will greatly frustrate efforts for taxpayers to claim the R&D tax credit, particularly by small manufacturers, which will hurt innovation and the high-paying jobs supported by slightly more than $300 billion the sector spent on R&D in 2022.2 Moreover, manufacturers would be impacted disproportionately by proposed changes given that manufacturing corporations“claimed nearly 60 percent of the total dollar value of research credits in 2017 ,” according to the Joint Committee on Taxation.3  \nAs the proposed Form 6765 changes are at odds with the statutory mandate to limit the compliance burden for claiming the research credit and will significantly increase the compliance burden on taxpayers claiming the research credit, the NAM respectfully requests  \n1 [https://www.irs.gov/newsroom/irs-requests-feedback-on-preview-of-proposed-changes-to-form-6765-credit-for-increasing](https://www.irs.gov/newsroom/irs-requests-feedback-on-preview-of-proposed-changes-to-form-6765-credit-for-increasing)research-activities  \n2 U.S. Bureau of Economic Analysis. Retrieved from [https://apps.bea.gov/iTable/?reqid=19&step=2&isuri=1&categories=survey](https://apps.bea.gov/iTable/?reqid=19&step=2&isuri=1&categories=survey).  \n3 Joint Committee on Taxation, Tax Incentives for Domestic Manufacturing (JCX-15-21) at 54 (March 12, 2021) .  \nthat the proposed changes to Form 6765 be withdrawn. In the event the IRS does not see fit to withdraw the Form 6765 changes, the NAM suggests certain modifications and clarifications to simplify the compliance process for claiming the research credit as well as delaying the proposed 2024 effective date by at least a year.  \nBackground on the R&D Tax Credit  \nGenerally speaking, the R&D tax credit comes in the form of either a regular4 or alternative simplified tax credit5 with both designed to incentivize R&D investments above a base amount. While each of these tax credits is computed differently, both are governed by a fourpart test6 and limit qualifying costs to the same types of expenses for purposes of computing the credit. The four-part test, which involves a fact-intensive analysis, is as follows:  \n1. Credit-eligible expenditures may be treated as specified research expenses under Section 174; meaning the expenditures are incurred for research activities intended to discover information that would eliminate uncertainty concerning the development or improvement of a product. Uncertainty exists if the information ava","cbCaig8QIRyq3djZ","https://ap.wps.com/l/cbCaig8QIRyq3djZ","pdf",270374,6,"English","# Background on the R&D Tax Credit\n## Four-part test for eligibility\n## Qualified expenses and recordkeeping\n# Proposed changes to Form 6765\n## Requested withdrawal\n## Suggested modifications and effective date delay","[{\"question\":\"Why does NAM oppose the proposed changes to Form 6765?\",\"answer\":\"NAM says the proposed new reporting requirements would impose extraordinary compliance costs, frustrate taxpayers’ ability to claim the credit (especially small manufacturers), and thereby threaten innovation and high-paying jobs.\"},{\"question\":\"What is the four-part test used to determine R\\u0026D tax credit eligibility?\",\"answer\":\"The test requires that expenditures are specified research expenses under Section 174, activities are technological in nature, they are intended to be useful in developing a new or improved business component, and substantially all activities constitute elements of a process of experimentation.\"},{\"question\":\"What does NAM request if the IRS does not withdraw the changes?\",\"answer\":\"NAM requests withdrawal; if not withdrawn, it suggests modifications and clarifications to simplify claiming compliance and to delay the proposed 2024 effective date by at least one year.\"}]","NAM Comment Letter - Proposed Changes to Form 6765, Credit for Increasing Research Activities | PDF",1789794752]