IRS Seeks Feedback on Draft Form 6765 Instructions for 2024

On December 20, 2024, the IRS released the long-awaited Draft Instructions for Form 6765, following the updated Draft Form 6765 published on December 12. These documents reflect key changes to how taxpayers will need to report qualified research expenses (QREs) and business components—especially for controlled groups and ASC 730 Directive filers.

What’s New?

The draft instructions include updates related to:

• Section G reporting for controlled groups
• Business component-level detail for Section G
• The ASC 730 Directive
• Statistical sampling methods

The IRS is actively requesting public feedback on these changes to improve clarity and implementation ahead of the 2024 filing season.

Submit Your Feedback

Tax professionals, corporate filers, and stakeholders can submit comments through June 30, 2025.

Send your feedback via email to: [email protected] and use the subject line: “Instructions for Form 6765.”

Helpful Links

• IRS Announcement and Feedback Instructions 
• Draft Instructions for Form 6765 (PDF) 
• Draft Form 6765 (PDF) 

Why This Matters

With increased IRS scrutiny and more complex documentation requirements, it’s crucial to stay ahead of changes to Form 6765. Companies that rely on the R&D tax credit—especially those filing as part of a controlled group—should review these drafts closely and provide feedback where clarity is needed.

If you have questions or would like support in reviewing or responding to the draft instructions, reach out to the MASSIE team.

Jason Massie, CPA, Esq.

As the Founder and President of MASSIE R&D Tax Credits, Jason is responsible for the quality, consistency, and integrity of our services. His strategic vision and leadership drive innovation within the company, encouraging collaboration and ne...