Form 6765 Section G: what it asks for and the records behind each business component

Is Section G required on your client's Form 6765?

It depends on the tax year and the filer. Section G is the business component information section of Form 6765, Credit for Increasing Research Activities, added when the IRS redesigned the form. The IRS has phased it in, with years in which it was optional and exceptions for some smaller filers, so the answer for any return comes from the Instructions for Form 6765 for that tax year. Check them before you scope the engagement, not after the credit study is finished.

The direction is not in doubt: the IRS wants credit claims tied to identifiable business components, with the information sought and the expenses behind each one. Companies that already organize engineering records by project find Section G manageable. Companies that do not will find it expensive. The related expensing rules are covered separately in Section 174A explained.

What Section G asks for

In summary, Section G collects information about each business component the claim relies on. The instructions set out the exact fields, the order of reporting and how many components must be listed; the paraphrase below is a planning aid, not a substitute for reading them.

Expect the largest components to carry the most documentation weight, and confirm any current thresholds or small-filer exceptions directly in the instructions. For which software activities can qualify in the first place, see R&D tax credit for software development.

How Section G applies in common client situations

Two rows matter beyond the credit. The contractor and customer-research questions are the same ownership questions a data licensing review asks: whether the company, its contractors or its customers own the work product and the records.

How to build the business component file

1. Start with the product or engineering leader, not the general ledger. Ask for the epics, projects or features worked on during the year.
2. Group them into business components and agree names that match the client's own records.
3. Map payroll and time to each component using time tracking, sprint assignments or an allocation method your firm accepts.
4. For each component, collect the ticket, pull request and design records that show the information sought and the alternatives evaluated.
5. Flag contractor and customer-funded work separately and pull the contracts.
6. Leave the records in the client's systems. Workpapers should reference them, not copy whole repositories.

What Section G work reveals about a client's records

Preparing Section G works like an x-ray of a client's engineering history. You learn whether tickets link to pull requests, whether design decisions are written down, how many systems the team uses and how many years the records go back. Clients with clean, connected records across several years fit the profile AI labs and data buyers look for when they license engineering histories through SourceX, provided the company also clears the baseline: 50+ full-time employees at peak (contractors excluded), a multi-year operating record, the right to license its data, and a sponsor such as the owner, CEO or CFO.

Keep the tax engagement and any licensing conversation apart. Raise licensing only after the return work is done, only with the CEO or CFO, and only as an option they are free to decline. Do not use tax return information to decide whom to approach, and do not describe a client's records to anyone outside the firm. If the client is interested, they can apply through your referral link, or you can submit the company with basic fit information once they agree. The accountants partner page explains the program for firms, and the guide to CAS growth at Top 100 accounting firms covers what that growth means for referral relationships.

Fee, disclosure and consent rules for CPA referral partners

Referral rewards to CPAs are shaped by professional and state rules, and those rules vary.

• The AICPA Code. ET 1.520 in the AICPA Code of Professional Conduct bars a member in public practice from accepting a commission for recommending a product or service to a client for whom the firm does attest work (audits, reviews, certain compilations or examinations of prospective financial information), and any permitted commission or referral fee has to be disclosed to the client. A credit-study client can also be an audit or review client, so check the attest list before anything else.
• State statutes. Florida regulates CPA contingent fees, commissions and referral fees in section 473.3205 of its statutes, including restrictions on referral fees connected with certain public accounting services and written disclosure of commissions. The linked text is the 2017 version, so check the current statute.
• Stricter state rules. State requirements can go beyond the AICPA Code. The New Jersey Society of CPAs' resource on commissions and contingent fees notes that a licensee there may not receive a contingent fee for preparing an original or amended tax return, which matters when a credit claim is made on an amended return.
• Tax reporting. Partners paid as independent contractors may receive a Form 1099-NEC. The reporting threshold changed recently, so check the IRS Instructions for Forms 1099-MISC and 1099-NEC for the year of payment and confirm with your tax adviser.

Partners earn 25% of the eligible platform fees SourceX actually collects from the referred company's licensing deals, capped at $100,000 per referred company. Rewards become payable only after the buyer pays and SourceX receives its fee; a lead, meeting or signed agreement alone does not trigger payment, and no reward is guaranteed. The reward is paid from SourceX's fee, not from the client's proceeds.

Questions to ask your ethics partner or counsel

• Does the firm perform any attest service for this client, and what does that mean for a referral reward?
• What does our state board require for disclosing referral fees, and in what form?
• Do our engagement letters or privacy notice limit how we use client information to suggest outside services?
• What consent is needed before any tax return information informs a recommendation?
• Who in the firm registers as the partner, and how is credit recorded internally, including after a merger such as those described in accounting firm M&A in 2026?
• How should the reward be reported and taxed for the firm or the individual?

This is general information, not legal, tax or financial advice. Confirm with your own counsel, tax adviser or professional body before acting.

Next step

When this season's Section G work shows a client with years of well-linked engineering records, check it against who qualifies and the company fit checker. After the return is filed and the client agrees, register as a partner and make the introduction.