Refundable credits and cash payouts

1Summary

The federal credit for increasing research activities under Section 41 is a credit against income tax.1 A company with no income tax to pay cannot use it in the year it is earned, and unused credits are generally carried back one year and forward twenty.2 For most claimants, therefore, the credit is a reduction in future tax, not cash. There are two main exceptions. A qualified small business may elect to use up to $500,000 of its credit a year against its payroll taxes, an election the IRS says is designed for a start-up with little or no income tax liability.3 And a company that has already paid income tax can claim a refund of it on an amended return.4

Several other countries pay research incentives in cash to smaller or loss-making companies. This paper asks whether the official record shows that the risk associated with success fees, fees calculated as a share of the credit, concentrates where credits are paid in cash, and if so why.

It finds that official bodies in the United Kingdom and Canada have recorded concerns about adviser fees and claim quality that are tied to cash or refundable credits, and that the IRS recorded the same concern for the employee retention credit, a different, refundable federal credit. It also finds that no official source measures how claims for cash credits are prepared or paid for. The paper sets out the case for success fees fairly before answering it. Swanson Reed's position is stated once, in a labeled box.

2The question

A fee calculated as a percentage of a research credit rises with the credit. That is true whatever form the credit takes. This paper considers whether the form matters: whether a credit that arrives as cash, soon after filing, changes the way that incentive works, and for whom.

The question matters for United States policy because the federal credit has two routes to cash that are used by exactly the kind of companies for which cash matters most: start-ups with little revenue, and companies that have paid tax in earlier years and claim it back. It also matters because other countries have operated cash credits for longer and on a larger scale, and their tax authorities have published what they found. Those findings are described here factually. This paper makes no recommendation for any country other than the United States.

3How the federal research credit reaches cash

3.1A credit against income tax

Section 41 generally allows a credit equal to 20 percent of qualified research expenses above a base amount, or 14 percent under the alternative simplified method.13 The IRS describes the credit as "generally applied against a taxpayer's income tax liability".3 Where a company's business credits exceed the limitation for the year, the excess is carried back to the preceding year and forward to each of the following twenty years.2

A company that is not yet profitable, or that is making losses, may therefore earn a credit it cannot use for some time. For that company, a credit is worth less today than its face value, and its value depends on future profits.

3.2The payroll tax election

Since tax years beginning after 2015, a qualified small business may elect to apply part of its research credit against the employer's share of payroll taxes.13 A qualified small business is broadly a corporation or partnership with gross receipts of less than $5,000,000 for the year and no gross receipts for any year before the five-year period ending with that year.1 The amount that may be elected was $250,000 and was increased to $500,000 for tax years beginning after 31 December 2022.3

The IRS states that the election "is designed to benefit an eligible startup that has little or no income tax liability", that it is made on Form 6765 attached to a timely filed income tax return, and that it cannot be made on an amended return.3 The credit is allowed against payroll tax from the first calendar quarter that begins after the return containing the election is filed, and it may not exceed the relevant employer tax for a quarter.5 For tax years beginning before 2023, the IRS states that the credit "may not be refunded in the absence of liability for the employer's portion of social security tax"; any excess is carried to the next quarter.3

The payroll election is therefore not a cash refund in the strict sense. It reduces a tax the company pays every quarter in which it has employees. In practice, for a start-up with a payroll, it turns a credit that might otherwise wait years for profits into a reduction in cash outflow within months of filing. A separate paper in this series describes the election in detail.

The Treasury Inspector General for Tax Administration (TIGTA) reported in April 2026 that the IRS had received 11,416 Forms 941 with $382 million of payroll tax credit for tax year 2023, and 12,612 Forms 941 with $381 million for tax year 2024, as of June 2025.6 It found that the IRS "still does not have processes to address ineligible taxpayers" who claim the credit, identified 40 businesses that did not meet the gross receipts requirement for tax year 2023 and had been allowed $3.1 million, and stated that most businesses that claim the credit are eligible.6 TIGTA's review concerned eligibility. It did not report on how the claims were prepared or how their preparers were paid.6

3.3Refund claims on amended returns

A company that has paid income tax in earlier years can claim the research credit for those years on an amended return and receive a refund. The IRS has said that each year it receives "thousands of R&E claims for credits in the hundreds of millions of dollars", and that research credit claims "are currently examined in a substantial number of cases and consume significant resources for both the IRS and taxpayers".7 Since January 2022 it has required specific information with research credit refund claims, and it states that it will "make every attempt" to determine such claims within six months of receipt.4

A refund claim produces cash in a lump sum, after filing and before any examination is complete. The 2008 IRS guide for examiners, which states that it is not an official pronouncement of IRS position, said that research credit refund claims "are usually based upon a Research Credit Study prepared by an outside consultant" and asked examiners to consider contingency fees when evaluating them.8

4What other countries' records show

Other countries pay research incentives in cash to some or all claimants. Their tax authorities have published estimates, warnings and policy changes that bear on the question. They are summarized here as each authority states them.

Country	Cash route for the research incentive	What the official record says about advisers or fees
United Kingdom	A payable credit under the former SME scheme, capped by reference to PAYE from April 2021; the schemes were merged from April 202491011	Error and fraud far higher in the SME scheme than in RDEC; nominations of credit payments to agents restricted to reduce "the financial incentive for agents to overstate claims"10
Canada	Refundable investment tax credits for some businesses12	A 2012 federal consultation recorded concern about contingency fees charged to small and medium-sized firms, whose enhanced credits were then generally fully refundable13
Ireland	The credit is paid in three annual instalments, each of which may be paid to the company14	No official statement on fees found for this paper

4.1United Kingdom

Until April 2024 the United Kingdom had two schemes: an SME scheme, which included a payable tax credit, and the research and development expenditure credit (RDEC) for large companies and others not eligible for the SME relief.911 From April 2021 the payable relief in the SME scheme was capped at £20,000 plus 300 percent of the company's PAYE and National Insurance liability.910 From April 2024 the two schemes were merged, with additional support for R&D intensive SMEs.11 HMRC introduced a mandatory random enquiry programme, a full audit of a random sample of SME claims, to measure non-compliance.9 Its published estimates for 2021 to 2022 put error and fraud at £1.2 billion, or 25.8 percent of the expenditure in the SME scheme, and £134 million, or 4.6 percent, in the RDEC scheme.10

The estimates published in HMRC's reports do not separate payable credits from other SME relief, so they do not show directly whether cash claims were less compliant than other SME claims. They do show that the scheme open to loss-making SMEs had the higher rate. The National Audit Office records that the Finance Act 2023 reduced the SME payable credit rate from 14.5 percent to 10 percent and the SME additional deduction from 130 percent to 86 percent, and that the legislation was, "in part, a response to the estimated level of error and fraud for the SME scheme being considerably higher than for the RDEC scheme".11

HMRC also acted on how cash moved. From April 2024 it restricted the use of nominations, under which R&D tax credit payments could be paid to a third party such as an agent, and prevented new assignments of the right to receive credits. HMRC said that payments would go directly to the claimant company, which would "help reduce non-compliance within the scheme by reducing the financial incentive for agents to overstate claims", and that "More than 90% of claims that are fraudulent or display some markers of fraud use nominee bank accounts."10 HMRC's guidance on correcting an overclaim adds that "Some agents deduct their fees before paying clients the balance of their R&D claim", and that a company repaying an overclaim must include the full amount overclaimed, "not the net amount you received".15

HMRC illustrated the point with a case study it labels illustrative: a small restaurant persuaded by an agent to claim, which receives £4,000 of relief, of which the agent takes £1,600 in fees, and which a year later must repay the £4,000 plus interest.10

4.2Canada

The CRA states that businesses may earn investment tax credits at a basic rate of 15 percent, that some corporations may claim an enhanced rate of 35 percent, and that "Some businesses may also earn a refundable ITC."12 In 2012 the Department of Finance consulted on contingency fees in the SR&ED program. Its consultation paper said that unused enhanced credits were "generally fully refundable for small and medium-sized CCPCs on their first $3 million of current expenditures", and that small and medium-sized businesses "sometimes rely on third-party tax preparers charging on a contingency-fee basis".13

The paper reported that such fees "may represent 30 per cent or more of the total SR&ED benefit received by these firms", and that the practice "has been criticized on the basis that it provides an incentive for tax preparers to encourage their clients to take aggressive positions that push the bounds of the law and its interpretation". It added: "If true, this practice would increase the costs for the Canada Revenue Agency to administer the SR&ED tax incentive program, in addition to increasing the overall fiscal risks".13 It also set out positive effects: marketing by preparers could spread knowledge of the program, and preparers may take on claims for businesses that would not otherwise claim.13 Those statements are the government's 2012 description of concerns it had heard. They are not findings.

In 2022 the CRA said it had "observed a recent increase in SR&ED claims containing false and/or non-compliant information" and advised businesses to be cautious of unsolicited offers to claim on their behalf.16

4.3Ireland

Revenue pays the R&D corporation tax credit in three annual instalments. For each instalment the company specifies whether it is to be offset against its tax liabilities or "paid to the company by Revenue".14 The credit can therefore reach a company as cash whether or not it has tax to pay. A separate paper in this series describes how that timetable interacts with when a success fee falls due. No official statement on adviser fees for Irish R&D claims was found for this paper.

5The United States record on a refundable credit

The United States has recent experience of a fully refundable business credit and of the fees charged to claim it. The employee retention credit is a different credit with different rules, and nothing in this section is evidence about research credit advisers. It is described because the IRS's own statements about it address the question this paper asks.

The IRS describes the employee retention credit as "a refundable tax credit".17 In April 2023 it warned that third parties were aggressively promoting claims and "charging the filer either large upfront fees or a fee that is contingent on the amount of their refund".18 In September 2023 it stopped processing new claims, citing "a flood of improper Employee Retention Credit claims", and stated that "a promoter can collect a contingency fee of up to 25% of the ERC refund".17 The Commissioner urged businesses to use a trusted tax professional, "not a promoter or marketer hustling to get a hefty contingency fee".17

When the IRS set up a voluntary disclosure program for businesses that had received the credit in error, it allowed them to repay 80 percent rather than the full amount. It explained: "The IRS selected an 80% repayment because many of the ERC promoters charged a percentage fee that they collected at the time of payment or in advance of the payment, and the recipients never received the full amount."19 That is an official acknowledgment that, where a refundable credit is paid out, a percentage fee may already have been taken from it before the credit is found to be wrong.

The IRS's list of warning signs for the credit includes "Fees based on a percentage of the refund amount of Employee Retention Credit claimed", with the advice that "you should always avoid a tax preparer basing their fee on the amount of the refund".20

6Why cash changes the incentive

The official statements above come from different countries and different credits. Read together, they point to three features of cash credits that bear on how a percentage fee works. What follows is analysis of those features, not a measured finding.

6.1The fee is paid from money already received

Where a credit reduces future tax, a fee calculated on it may be due before the company has gained anything. Where the credit is paid in cash, the fee can be paid from the cash itself, and in some arrangements deducted before the balance reaches the company.1519 That makes a percentage fee easier to agree to: the company does not need to find the money. It also means that, if the credit is later reduced, the fee has already left the company, while the obligation to repay the full credit stays with it.1519

Federal law already recognizes the risk of refund money passing through a practitioner's hands. Circular 230 provides that a practitioner may not endorse or otherwise negotiate a check issued to a client by the government in respect of a federal tax liability, including by directing payment into an account the practitioner controls.21

6.2The companies have the least room for error

Cash routes are designed for companies that cannot use a credit against income tax: start-ups, loss-making companies and smaller firms.313 Those companies are the least likely to have in-house tax staff who can test a claim prepared for them, and the most likely to be harmed if a credit they have spent must be repaid. HMRC found in 2023 that 38 percent of the value of first-time claims was non-compliant, against 22 percent for companies that had claimed before.9

6.3The money arrives before review

A refund claim or a payroll offset reaches the company soon after filing. Examination, if it happens, comes later.45 HMRC states that post-payment checks let customers "receive payment quickly but can result in uncertainty for customers about whether their claim might later be found to be non-compliant and their payment recovered".10 Where a fee is calculated on the amount paid, it is settled before that uncertainty is resolved.

6.4Who repays

In the United States, if a refund claim is excessive, the person making the claim is liable for a penalty of 20 percent of the excessive amount unless the excess is due to reasonable cause, and interest runs on unpaid tax from the date it was due.2223 The person making the claim is the taxpayer. For the payroll election, Section 41(h) directs Treasury to prescribe regulations for recapturing the benefit where the payroll tax credit portion is later adjusted.1 No federal rule requires an adviser to refund a contingent fee when a claim is reduced.

7The rules that already apply

Circular 230 prohibits a practitioner from charging a contingent fee for services in connection with any matter before the IRS, which includes preparing returns and claims for refund, subject to exceptions for examinations, certain claims filed within 120 days of a notice of examination, interest and penalty claims, and judicial proceedings.21 It defines a contingent fee to include "a fee that is based on a percentage of the refund reported on a return".21 The AICPA Code provides that a member in public practice shall not "Prepare an original or amended tax return or claim for a tax refund for a contingent fee for any client".24

Those rules do not reach every preparer. In December 2024 Treasury and the IRS recorded that a federal court had "concluded that the IRS cannot prohibit charging contingent fees for ordinary refund claims based on its authority to regulate practice before the IRS", and proposed instead to treat contingent fees for preparing returns and refund claims as disreputable conduct, because "A practitioner with a direct, financial interest in the tax benefits of a client may be incentivized to increase such tax benefits."25 The proposal would apply to practitioners, and the Federal Register showed no final rule as of 11 October 2026.25

8The case for success fees where credits are paid in cash

The case for success fees is strongest for exactly the companies that receive credits in cash, and it should be stated in its strongest form.

No money up front. A start-up or loss-making company is short of cash. A fee paid from the credit when it arrives costs nothing in advance. Without it, some companies would not claim a credit that was designed for them.

The cash is there to pay it. Because the credit arrives as cash, the company can pay a percentage fee without borrowing or diverting working capital. The fee is matched to the benefit in both amount and timing.

The adviser carries the risk of no result. If the work finds no credit, the company pays nothing. A fixed fee would leave that cost with the company.

Access to expertise. Small companies rarely have tax staff. Contingent pricing lets them hire specialists they could not otherwise afford. Canada's 2012 consultation itself noted that preparers may take on claims for businesses that would not otherwise have claimed.13

These are real advantages. Nothing in this paper suggests that advisers who charge success fees for cash credits act improperly, and the official statements quoted above concern particular practices, not advisers who charge percentage fees in general.

9Answering the case

9.1Timing is not the same as calculation

The cash argument is about when a fee is paid. It does not require the fee to be calculated as a share of the credit. Because a cash credit arrives soon after filing, a fixed or capped fee agreed in advance can be paid from it on the same timetable. Treasury's definition of a contingent fee concerns how the fee is calculated, not when it is paid.21

9.2The risk that matters stays with the company

A percentage fee transfers to the adviser the risk that no credit is found. It does not transfer the risk that the credit paid out is later reduced. That risk, with interest and possibly a 20 percent penalty, stays with the company, and it falls hardest on companies that have already spent the cash.222319

9.3Matching the benefit is not matching the outcome

A fee tied to the amount paid moves with the amount claimed, not with the amount that survives review. The IRS's decision to accept 80 percent repayment under its employee retention credit program, because fees had already been taken from the payouts, shows how far apart those two amounts can be.19

9.4Access is a reason for clear pricing

The access argument is a reason for affordable and predictable fees. Fixed, capped or staged fees meet it. The CRA, for example, offers a free telephone consultation and a self-assessment tool to businesses considering a claim.16

Our position

Congress should prohibit contingent fees, commonly called success fees, in federal research and development tax credit engagements under Section 41, so that advisers are paid for the work they perform rather than for the size of the claim they produce. That includes claims that reach a company as a payroll tax reduction or as a refund. Swanson Reed, which publishes this paper, is a fixed-fee R&D tax adviser. It has a direct commercial interest in the outcome: it does not charge success fees, and a ban would remove a pricing model it competes against.

10What the evidence does and does not show

What the record shows:

The federal research credit reaches cash mainly through the payroll tax election for qualified small businesses and through refund claims.34
In the United Kingdom, measured error and fraud was far higher in the scheme open to loss-making SMEs than in RDEC, and the government cut the SME payable credit partly in response.1011
HMRC restricted payments of credits to agents to reduce the incentive to overstate claims.10
A 2012 Canadian federal consultation and the IRS (for the employee retention credit) have each linked concerns about percentage fees to credits paid as cash.1317

What the record does not show:

How many federal payroll offset or refund claims are prepared for a percentage fee.
Whether cash claims prepared for a percentage fee are adjusted more often than others, in the United States or elsewhere. The estimates published in HMRC's reports do not separate payable credits from other SME relief, and the TIGTA reviews concern eligibility only.106

The case made here therefore rests on official statements, the structure of the fee and the design of cash credits, not on measured outcomes. Readers who disagree with the position above should weigh it on that basis.

References

Office of the Law Revision Counsel, 26 U.S.C. 41, Credit for increasing research activities, subsections (a) and (h), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapA-partIV-subpartD-sec41.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 39, Carryback and carryforward of unused credits, subsection (a)(1), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapA-partIV-subpartD-sec39.htm (accessed 11 October 2026). Back
Internal Revenue Service, Qualified small business payroll tax credit for increasing research activities (page last reviewed or updated 28 June 2026). https://www.irs.gov/businesses/small-businesses-self-employed/qualified-small-business-payroll-tax-credit-for-increasing-research-activities (accessed 11 October 2026). Back
Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions, introduction and questions 5 and 7 (page last reviewed or updated 1 October 2026). https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 3111, Rate of tax, subsection (f)(1) and (2), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleC-chap21-subchapB-sec3111.htm (accessed 11 October 2026). Back
Treasury Inspector General for Tax Administration, Controls for the Qualified Small Business Payroll Tax Credit Were Updated, but Ineligible Taxpayers Continue to Receive the Credit, Report Number 2026-408-012 (15 April 2026), Highlights and Background. https://www.tigta.gov/sites/default/files/reports/2026-04/2026408012fr.pdf (accessed 11 October 2026). Back
Internal Revenue Service, IRS sets forth required information for a valid research credit claim for refund, News release IR-2021-203, 15 October 2021. https://www.irs.gov/newsroom/irs-sets-forth-required-information-for-a-valid-research-credit-claim-for-refund (accessed 11 October 2026). Back
Internal Revenue Service, Large and Mid Size Business Division, Research Credit Claims Audit Techniques Guide (RCCATG): Credit for Increasing Research Activities Section 41, LMSB-04-0508-030 (May 2008), introductory note and Chapter II, "Additional areas to consider" and "The RC Claim Engagement Letter". https://www.irs.gov/businesses/research-credit-claims-audit-techniques-guide-rccatg-credit-for-increasing-research-activities-section-41 (accessed 11 October 2026). Back
HM Revenue and Customs, HMRC's approach to Research and Development tax reliefs (published 17 July 2023), sections 1.1, 1.2, 3.1 and 3.2, Theme 4. https://www.gov.uk/government/publications/compliance-approach-to-research-and-development-tax-reliefs/hmrcs-approach-to-research-and-development-tax-reliefs (accessed 11 October 2026). Back
HM Revenue and Customs, Approach to Research and Development tax reliefs 2023 to 2024 (published 30 October 2024), sections 1.2, 2.1, 2.3 and 2.4 and Annex A. https://www.gov.uk/government/publications/hmrcs-approach-to-research-and-development-tax-reliefs-2023-to-2024/approach-to-research-and-development-tax-reliefs-2023-to-2024 (accessed 11 October 2026). Back
National Audit Office, Report by the Comptroller and Auditor General: HM Revenue & Customs 2023-24 Accounts, paragraphs 2.10, 2.19 and 2.20. https://assets.publishing.service.gov.uk/media/6889f286048fff613a4d5b72/Report_by_the_Comptroller_and_Auditor_General.pdf (accessed 11 October 2026). Back
Canada Revenue Agency, What are SR&ED tax incentives, section "Earn an investment tax credit (ITC)". https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/what-are-sred-tax-incentives.html (accessed 11 October 2026). Back
Department of Finance Canada, Consultation Regarding the Impact of Contingency Fees on the Effectiveness of the SR&ED Tax Incentive Program (2012), sections "Overview", "Background", "Rationale for Contingency Fees" and "Effects of Contingency Fees", archived copy of 7 May 2013. https://web.archive.org/web/20130507033404/http://www.fin.gc.ca/activty/consult/sred-rsde-eng.asp (accessed 11 October 2026). Back
Revenue Commissioners, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), section 2.3. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-29/29-02-03.pdf (accessed 11 October 2026). Back
HM Revenue and Customs, Tell HMRC if you've claimed too much Research and Development (R&D) tax relief (published 31 December 2024, last updated 14 August 2026), section "Make your disclosure". https://www.gov.uk/guidance/tell-hmrc-if-youve-claimed-too-much-research-and-development-rd-tax-relief (accessed 11 October 2026). Back
Canada Revenue Agency, Advisory for businesses claiming SR&ED investment tax credits (12 October 2022). https://www.canada.ca/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2022/advisory-businesses-claiming-sred-investment-tax-credits.html (accessed 11 October 2026). Back
Internal Revenue Service, News release IR-2023-169 announcing a moratorium on processing new Employee Retention Credit claims, 14 September 2023. https://www.irs.gov/newsroom/to-protect-taxpayers-from-scams-irs-orders-immediate-stop-to-new-employee-retention-credit-processing-amid-surge-of-questionable-claims-concerns-from-tax-pros (accessed 11 October 2026). Back
Internal Revenue Service, Employers: Watch out for Employee Retention Credit schemes, IRS Tax Tip 2023-44, 4 April 2023. https://www.irs.gov/newsroom/employers-watch-out-for-employee-retention-credit-schemes (accessed 11 October 2026). Back
Internal Revenue Service, IRS new Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back at discounted rate, News release IR-2023-247, 21 December 2023. https://www.irs.gov/newsroom/irs-new-voluntary-disclosure-program-lets-employers-who-received-questionable-employee-retention-credits-pay-them-back-at-discounted-rate-interested-taxpayers-must-apply-by-march-22 (accessed 11 October 2026). Back
Internal Revenue Service, Employee Retention Credit, section "Look for these warning signs" (page last reviewed or updated 8 October 2026). https://www.irs.gov/coronavirus/employee-retention-credit (accessed 11 October 2026). Back
Treasury Department, Circular No. 230, 31 CFR 10.27, Fees, paragraphs (b) and (c), and 31 CFR 10.31, Negotiation of taxpayer checks, paragraph (a). https://www.ecfr.gov/current/title-31/subtitle-A/part-10 (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6676, Erroneous claim for refund or credit, subsections (a) and (b), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapB-partI-sec6676.htm (accessed 11 October 2026). Back
Office of the Law Revision Counsel, 26 U.S.C. 6601, Interest on underpayment, nonpayment, or extensions of time for payment, of tax, subsection (a), United States Code 2024 edition published by the Government Publishing Office. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap67-subchapA-sec6601.htm (accessed 11 October 2026). Back
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Cite this paper

Summary

1Summary

2The question

3How the federal research credit reaches cash

3.1A credit against income tax

3.2The payroll tax election

3.3Refund claims on amended returns

4What other countries' records show

4.1United Kingdom

4.2Canada

4.3Ireland

5The United States record on a refundable credit

6Why cash changes the incentive

6.1The fee is paid from money already received

6.2The companies have the least room for error

6.3The money arrives before review

6.4Who repays

7The rules that already apply

8The case for success fees where credits are paid in cash

9Answering the case

9.1Timing is not the same as calculation

9.2The risk that matters stays with the company

9.3Matching the benefit is not matching the outcome

9.4Access is a reason for clear pricing

10What the evidence does and does not show

References

About this paper

Cite this paper

Summary

1Summary

2The question

3How the federal research credit reaches cash

3.1A credit against income tax

3.2The payroll tax election

3.3Refund claims on amended returns

4What other countries' records show

4.1United Kingdom

4.2Canada

4.3Ireland

5The United States record on a refundable credit

6Why cash changes the incentive

6.1The fee is paid from money already received

6.2The companies have the least room for error

6.3The money arrives before review

6.4Who repays

7The rules that already apply

8The case for success fees where credits are paid in cash

9Answering the case

9.1Timing is not the same as calculation

9.2The risk that matters stays with the company

9.3Matching the benefit is not matching the outcome

9.4Access is a reason for clear pricing

10What the evidence does and does not show

References

About this paper

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