IRS Delays Section G of Form 6765 to 2026; and Refund Claims now perfected through January 10, 2027

The IRS released Notice 2025-99 (IR-2025-99) on October 1, 2025. In this update, the agency extended the deadline for feedback on the new reporting requirements for the Research Credit. The notice affects Form 6765, Credit for Increasing Research Activities, and gives taxpayers more breathing room before the new rules take effect.

Here’s what changed:

• More time for comments: The IRS pushed the feedback deadline for the draft Form 6765 instructions to March 31, 2026. This extension allows companies to review the proposed changes and share input before they become final.

• Section G remains optional for now: For the 2025 tax year, filers can still choose whether to complete Section G of Form 6765. This section asks for detailed business component information. By delaying the mandate, the IRS is giving taxpayers extra time to adjust their systems and documentation.

• Mandatory in 2026: Beginning with the 2026 tax year, most filers will need to complete Section G. However, certain qualified small businesses and taxpayers with limited research expenses may continue to qualify for exceptions.

• Longer refund-claim window: The IRS also extended the period for perfecting research credit refund claims through January 10, 2027. This change gives taxpayers an additional 45 days to finalize their claims before the agency makes a determination.

• Updated instructions coming soon: Finally, the IRS plans to release revised Form 6765 instructions in January 2026, so taxpayers will have time to prepare for the 2026 filing season.

Source: IRS Release 2025-99