These proposals are the position of Swanson Reed, the publisher of this site.
Entries are dated summaries of public documents. Check the linked source for the current position.
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October 2025
- IRS extends the period for feedback on Form 6765 (IR-2025-99)
IRS confirms Form 6765 Section G becomes mandatory for tax year 2026
The IRS said Section G (business component information) of Form 6765 is optional for tax year 2025 and mandatory for tax year 2026 and later, with optional reporting for certain qualified small businesses and smaller filers. It also said the transition period to perfect research credit refund claims runs through 10 January 2027.
May 2025
- H.R. 1, 119th Congress, Engrossed in House
House passes H.R. 1 with a section restricting Treasury regulation of contingent fees
Section 112208 of H.R. 1 as passed by the House provided that the Secretary of the Treasury may not regulate, prohibit or restrict the use of a contingent fee in connection with tax returns or claims for refund. The text enacted as Public Law 119-21 on 4 July 2025 does not contain this section.
December 2024
- Regulations Governing Practice Before the Internal Revenue Service (REG-116610-20), 89 FR 104915
Treasury proposes treating contingent fees for return and refund claim preparation as disreputable conduct
Proposed amendments to Circular 230 would remove section 10.27 and add section 10.51, under which charging a contingent fee for preparing an original or amended return or a refund claim before examination would be disreputable conduct. Comments were due by 24 February 2025.
June 2024
- Research credit claims (Section 41) on amended returns frequently asked questions
IRS reduces required items for research credit refund claims from five to three
Effective 18 June 2024, the IRS waived the requirement to give the names of the individuals who performed each research activity and the information each sought to discover. Claims must still identify business components and research activities and give total qualified expenses.
August 2023
- CIRD182000, R&D Tax Reliefs: reformed reliefs: claims process: additional information form
Additional information required for all R&D relief claims
For claims made on or after 8 August 2023, claimants must provide the information specified in SI 2023/813, Schedule 2, on or before the date the claim is made. The additional information form asks whether the company has a tax agent for the R&D claim and, if so, for the agent's details.
April 2023
- CIRD183000, R&D Tax Reliefs: reformed reliefs: claims process: pre-notification of claims
Claim notification required for R&D relief claims
For accounting periods beginning on or after 1 April 2023, a company must notify HMRC of an intended R&D claim within the claim notification period unless an exception applies, such as an R&D claim made in the three years ending with the last day of that period. The content of the notification, including agent or tax adviser details, is set by SI 2023/813, Schedule 1.
October 2021
- Memorandum 20214101F, I.R.C. section 41 Research Credit Refund Claims
IRS Chief Counsel memorandum sets out information required for research credit refund claims
Memorandum 20214101F states that a valid Section 41 refund claim must identify the business components, the research activities, the individuals who performed them and the information each sought to discover, and give total qualified wage, supply and contract research expenses.
October 2013
- SR&ED T661 Claim Form: 2013 revision, claim preparer information
CRA revises Form T661 to add Part 9, claim preparer information
Following the March 2013 federal budget, Form T661 asks for each SR&ED claim preparer's details and billing arrangement, including the billing rate and total fee. A penalty of $1,000 may be assessed for each claim with missing, incomplete or inaccurate preparer information, for which the claim preparer is jointly and severally liable with the claimant.

