A CPA or other qualified tax professional often reviews an R&D tax credit claim before it is filed. This page explains, in general terms, what such a review may involve and how organized records can support it. It is an educational description of a reasonable workflow, not a statement of professional standards or legally mandated procedures. Different professionals may approach the review differently. This page is educational and is not individualized advice. For the documentation concepts, see our page on R&D tax credit documentation.
What a CPA May Review
A professional reviewing a credit claim may examine the activities asserted to be qualified research, the costs asserted to be qualified research expenses, the documentation supporting both, and the form on which the credit is reported. The review generally focuses on whether the activities and costs meet the requirements of Section 41 and the Treasury Regulations, and whether the claim is supportable. For the substantive rules, see our page on what the R&D tax credit is.
Understanding the Business and Projects
A review often begins with understanding the taxpayer's business and the specific projects and business components involved. Context about what the company does, what it was trying to develop or improve, and how the work was organized helps the reviewer evaluate whether the activities may constitute qualified research.
Reviewing Qualified Research
The reviewer may examine whether the activities satisfy the requirements of Section 41(d) — the four-part test. This includes whether the work was undertaken for a permitted purpose, was technological in nature, was intended to eliminate uncertainty, and was conducted through a process of experimentation, and whether any excluded activities (such as research after commercial production, funded research, or foreign research) are involved. For more, see our page on qualified research.
Reviewing the Four-Part Test
For each business component, the reviewer may look for support for each element of the four-part test — the technical uncertainty, the alternatives evaluated, the evaluative process, and the connection to a business component. Records created during the work tend to be more useful than generalized descriptions prepared later. For more, see our page on the four-part test.
Reviewing Qualified Research Expenses
The reviewer may examine the costs taken into account — certain wages, certain supplies, and certain contract research — and whether they meet the requirements of Section 41(b) and the Treasury Regulations (§1.41-2). This includes whether the costs are connected to qualified research activities and whether allocations between qualified research and other work are supportable. For more, see our page on qualified research expenses.
Employee Wage Support
For wages, the reviewer may look at who is included, whether their services fall within the qualified-services categories (direct research, direct supervision, direct support), and whether time allocations are supportable. Job title alone does not determine treatment. For more, see our page on R&D tax credit employee wages.
Contractor and Supply Records
For contractor costs, the reviewer may examine whether the taxpayer bears the economic risk and retains substantial rights to the results, and whether the research was performed in the United States. For supplies, the reviewer may examine whether the items meet the statutory definition and are connected to qualified research. For more, see our pages on contractor costs and supplies.
Form 6765 Information
The reviewer may examine the information reported on Form 6765, including the computation method, the qualified research expenses, and the business-component information. The current form and instructions control the specific reporting requirements. For more, see our page on Form 6765.
Documentation Gaps and Follow-Up Questions
A review often identifies gaps — activities described only at a departmental level, costs allocated without a supportable connection, or missing records of the technical uncertainty or process of experimentation. The reviewer may ask follow-up questions or request additional records. Identifying and addressing gaps before filing is generally preferable to reconstructing records later. For more, see our page on R&D tax credit recordkeeping.
Preparing an Accountant-Ready Record Set
Organized records can make the review more efficient. A record set that connects activities, costs, and business components, addresses the four-part test, and identifies the personnel and locations involved can help a professional evaluate the claim. For more on assembling such records, see our page on how to document R&D projects.
Why Organized Records Matter
Organized records tend to make a review more straightforward and a claim more defensible. They help the reviewer focus on the substantive questions rather than on locating or reconstructing information. Disorganized or reconstructed records can make the review harder and the claim less supportable.
R&D Ledger's Role vs. the CPA's Role
It is important to distinguish documentation preparation from professional tax judgment. R&D Ledger provides a workspace for organizing R&D projects, technical documentation, costs, and evidence — supporting the preparation and organization of records. A CPA or other qualified tax professional provides the professional tax analysis, applies the legal requirements to the facts, and makes filing decisions. R&D Ledger does not replace professional tax judgment, does not determine whether a taxpayer qualifies, and does not provide tax, legal, or accounting advice.
Key Takeaway
A CPA or qualified tax professional may review qualified research, the four-part test, qualified research expenses, and Form 6765 information, and organized records can support that review. Documentation preparation is distinct from professional tax judgment and filing decisions, and R&D Ledger's role is to help organize records, not to replace professional review. Because credit qualification is fact-specific, professional review is appropriate before claiming the credit.