Fee regulation timeline

United States. The federal research credit was enacted by Public Law 97-34, originally as section 44F of the Internal Revenue Code. It was later renumbered, and has been section 41 since 1986.1Source 126 U.S.C. section 41, historical and amendment notes (Pub. L. 97-34, title II, section 221(a), Aug. 13, 1981; Pub. L. 114-113, div. Q, title I, section 121, Dec. 18, 2015), United States Code, 2024 edition, GovInfo. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapA-partIV-subpartD-sec41.htm (accessed 11 October 2026).

United States. Public Law 110-28 added section 6676 to the Internal Revenue Code, a penalty of 20 percent of the excessive amount where a claim for refund or credit is made for an excessive amount. It applied to claims filed or submitted after that date.2Source 226 U.S.C. section 6676, subsection (a) and notes (Pub. L. 110-28, May 25, 2007; Pub. L. 114-113, section 209, Dec. 18, 2015), United States Code, 2024 edition, GovInfo. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapB-partI-sec6676.htm (accessed 11 October 2026).

United States. Section 10.27 of Circular 230, which restricts contingent fees for matters before the IRS, applies to fee arrangements entered into after this date, according to its applicability provision.3Source 3Treasury Department, Circular No. 230 (Rev. 6-2014), 31 CFR section 10.27(d) (Effective/applicability date). https://www.irs.gov/pub/irs-pdf/pcir230.pdf (accessed 11 October 2026).

Canada. The CRA states that the $1,000 penalty for missing, incomplete or inaccurate SR&ED claim preparer information applies to claims filed on or after the later of January 1, 2014 and the day the enacting legislation received royal assent. Part 9 of Form T661 asks for each claim preparer's billing arrangement and fees.4Source 4Canada Revenue Agency, SR&ED T661 Claim Form, 2013 Revision, Claim preparer information, Canada.ca. https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/whats-new-program/t661-claim-form-2013-revision-claim-preparer-information.html (accessed 11 October 2026).

United States. Treasury published the revised regulations governing practice before the IRS (Circular 230, Rev. 6-2014), which include the current text of section 10.27 on fees.5Source 5Treasury Department, Circular No. 230, Regulations Governing Practice before the Internal Revenue Service (Rev. 6-2014), cover page ("published (June 12, 2014)"). https://www.irs.gov/pub/irs-pdf/pcir230.pdf (accessed 11 October 2026).

United States. In Ridgely v. Lew, the US District Court for the District of Columbia held that the IRS lacked statutory authority to restrict contingent fees for preparing and filing ordinary refund claims, meaning claims filed after the original return but before the IRS begins an audit. The court granted a permanent injunction against enforcement in that setting.6Source 6Ridgely v. Lew, Civil Action No. 1:12-cv-00565 (CRC) (D.D.C. July 16, 2014), Memorandum Opinion (Document 48), pages 1 and 14 to 15. https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_12-cv-00565/pdf/USCOURTS-dcd-1_12-cv-00565-1.pdf (accessed 11 October 2026).

United States. Public Law 114-113 removed the termination date from section 41, so the research credit no longer had an expiry date.1Source 126 U.S.C. section 41, historical and amendment notes (Pub. L. 97-34, title II, section 221(a), Aug. 13, 1981; Pub. L. 114-113, div. Q, title I, section 121, Dec. 18, 2015), United States Code, 2024 edition, GovInfo. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapA-partIV-subpartD-sec41.htm (accessed 11 October 2026). The same law changed the section 6676 penalty standard from "reasonable basis" to "reasonable cause", for claims filed after that date.2Source 226 U.S.C. section 6676, subsection (a) and notes (Pub. L. 110-28, May 25, 2007; Pub. L. 114-113, section 209, Dec. 18, 2015), United States Code, 2024 edition, GovInfo. https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleF-chap68-subchapB-partI-sec6676.htm (accessed 11 October 2026).

United States. The IRS Office of Chief Counsel published a memorandum (FAA 20214101F) setting out the information a research credit refund claim must contain to be valid.7Source 7Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions. https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026).

United States. The grace period ended, and research credit refund claims were required to include the specified items of information, including the business components, the research activities, the individuals who performed them, the information each sought to discover, and the total qualified research expenses.7Source 7Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions. https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026).

United Kingdom. Claim notification rules apply to R&D relief claims for accounting periods beginning on or after this date. The notification must be made within six months of the end of the period of account unless an exception applies.8Source 8HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD183000 (pre-notification of claims). https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird183000 (accessed 11 October 2026).

United Kingdom. From this date, in practice, companies claiming R&D relief must submit an Additional Information Form before or with the claim.9Source 9HM Revenue and Customs, Corporate Intangibles Research and Development Manual, CIRD182000 (additional information form). https://www.gov.uk/hmrc-internal-manuals/corporate-intangibles-research-and-development-manual/cird182000 (accessed 11 October 2026). The form asks for contact details of all agents involved in the claim.10Source 10HM Revenue and Customs, Additional information you must submit before you claim Research and Development tax relief, GOV.UK. https://www.gov.uk/guidance/submit-detailed-information-before-you-claim-research-and-development-rd-tax-relief (accessed 11 October 2026).

United Kingdom. The merged R&D expenditure credit scheme applies to accounting periods beginning on or after this date.11Source 11HM Revenue and Customs, Research and Development (R&D) tax relief: the merged R&D expenditure credit scheme and enhanced R&D intensive support, GOV.UK. https://www.gov.uk/guidance/research-and-development-rd-tax-relief-the-merged-scheme-and-enhanced-rd-intensive-support (accessed 11 October 2026).

United States. The IRS stopped requiring research credit refund claims to name the individuals who performed each research activity and the information each sought to discover. The IRS may still request this information in an examination.7Source 7Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions. https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026).

United States. The IRS states that the transition period for research credit refund claims runs through this date. During the transition period, a taxpayer whose claim lacks required information has 45 days to perfect it.7Source 7Internal Revenue Service, Research credit claims (Section 41) on amended returns frequently asked questions. https://www.irs.gov/businesses/corporations/research-credit-claims-section-41-on-amended-returns-frequently-asked-questions (accessed 11 October 2026).