Special Review Topics

Can a Company With Outsourced Manufacturing Have R&D Activities?

A company with outsourced manufacturing may have R&D activities if it conducts qualified research in the United States. Outsourced manufacturing does not preclude R&D.

A common question is whether a company with outsourced manufacturing can have R&D activities for the federal R&D tax credit under Section 41. The short answer is that a company with outsourced manufacturing may have R&D activities if it conducts qualified research in the United States. This page explains the framework in general terms. It is educational and is not individualized advice. For the foundational framework, see our page on qualified research.

Key Considerations

The analysis depends on the specific facts and circumstances. Under the four-part test, qualified research must be for a permitted purpose, be technological in nature, be intended to eliminate uncertainty, and be conducted through a process of experimentation.

Common scenarios that may warrant review include:

  • New development — evaluating alternative approaches to resolve uncertainty about whether a new approach can achieve the required performance.
  • New arrangement — evaluating alternative approaches to resolve uncertainty about whether a new arrangement can achieve the required outcome.
  • New application — evaluating alternative approaches to resolve uncertainty about whether an existing approach can perform in a new context.
  • New requirement — evaluating alternative approaches to resolve uncertainty about whether a new requirement can be met.

Funded-Research Considerations

The funded-research exclusion under Section 41(d)(4)(H) may apply. The analysis examines whether the taxpayer bears the economic risk of failure and retains substantial rights in the research results.

Hypothetical Example

Consider a company that is evaluating a new approach and is uncertain whether any available method can achieve the required outcome. The company evaluates alternative approaches, tests each, and systematically varies the approach to resolve the uncertainty. This may warrant review as qualified research.

By contrast, if the same company performs routine work using established methods, that is routine work, not research.

This example is illustrative only and does not state that the activity definitely qualifies.

Documentation That May Help

Records that can help support this work include records identifying the uncertainty and alternative approaches, test results, and records of how results informed decisions. For more, see our page on R&D tax credit documentation.

Key Takeaway

A company with outsourced manufacturing may have R&D activities if it conducts qualified research in the United States. Outsourced manufacturing does not preclude R&D. Because the analysis is fact-specific, professional review is appropriate before claiming the credit.

Sources

  1. Treasury Regulation §1.41-4

    Cornell Law Institute (LII)

    Defines the process of experimentation as an evaluative process of alternatives and the elimination-of-uncertainty requirement.

  2. Internal Revenue Code §41

    Cornell Law Institute (LII)

    Section 41(d) defines qualified research and the four-part test.

  3. Instructions for Form 6765

    Internal Revenue Service

    Summarizes qualified research and excluded activities.

  4. Research Credit

    Internal Revenue Service

    IRS landing page for the Credit for Increasing Research Activities.

By R&D Ledger Editorial Team

Last reviewed: August 2026

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