R&D Tax Credit — Electronics & Medical Manufacturing

R&D Tax Credit for Semiconductor Design: Architecture, Logic, and Verification Development

Semiconductor design companies may perform technical work warranting analysis under IRC §41 — developing chip architectures, logic designs, verification methods, and simulation approaches for performance and power targets. Routine design iteration does not automatically qualify.

Semiconductor design companies develop the architecture, logic, and physical layout of integrated circuits — the chips that power computing, communications, automotive, and consumer electronics. The technical challenges can include developing chip architectures for performance and power targets, engineering logic designs, resolving thermal issues, developing verification and simulation methods, and evaluating design alternatives for timing and area. This page explains what development work may look like in a semiconductor design business and how it relates to qualified research under Section 41. It is educational and is not individualized advice.

What R&D May Look Like in Semiconductor Design

Semiconductor design involves architecture development, logic design, physical design, verification, and simulation. Technical development may arise when a company develops a new architecture for a performance or power target, evaluates alternative logic approaches, develops verification methods for complex designs, or optimizes physical design for thermal or timing targets. Work directed at resolving genuine technical uncertainty in these areas — through a structured evaluative process — may warrant review under the four-part test.

Industry-Specific Examples of Technical Development

  • Developing chip architectures for performance and power targets where the capability is uncertain.
  • Engineering logic designs for area or timing where the performance is uncertain.
  • Developing verification methods for complex designs where the coverage is uncertain.
  • Optimizing physical design for thermal or timing where the behavior is uncertain.
  • Evaluating design alternatives for power, performance, or area where the trade-offs are not established.

None of these constitutes qualified research by itself. Each depends on whether the work satisfies all four elements of the four-part test.

Technical Uncertainty Examples

  • Whether a new architecture can achieve the specified performance and power targets simultaneously.
  • Whether an alternative logic approach can achieve the specified timing target within the area constraint.
  • Whether a new verification method can achieve the specified coverage target for a complex design.

For more, see our page on elimination of uncertainty.

Process-of-Experimentation Examples

  • Developing and simulating alternative architectures, measuring performance and power, and comparing results.
  • Implementing alternative logic approaches, running timing analysis, and evaluating results.
  • Developing alternative verification methods, measuring coverage, and comparing results.

For more, see our page on process of experimentation.

Potential Business Components

Potential business components may include a new or improved product (a chip with improved performance or power), a new or improved technique (a verification or simulation method), or a new or improved process (a design flow or physical design approach).

Employee Work That May Warrant Analysis

Employees whose work may warrant analysis include architects developing chip architectures, logic engineers developing designs, verification engineers developing methods, and physical engineers developing layouts tied to a development project. For more, see our page on R&D tax credit employee wages.

Contractor Work That May Warrant Analysis

Contractor work that may warrant analysis includes IP vendors, design service providers, and simulation tool vendors co-developing approaches — where the company bears the economic risk and retains substantial rights. For more, see our page on R&D tax credit contractor costs.

Supplies and Materials That May Become Relevant

Supplies in semiconductor design are often limited because the work is primarily computational. Where tangible materials are consumed in prototyping or testing (e.g., test silicon, evaluation boards), they may become relevant. For more, see our page on R&D tax credit supplies.

Activities That Generally Require Caution or May Not Qualify

  • Routine design iteration using established flows and tools.
  • Standard verification runs using established methods.
  • Ordinary bug fixing and regression testing.
  • Copying or porting an existing design to a new process node without resolving technical uncertainty.
  • Normal quality control and review following established procedures.

Documentation That May Help

Records that may help include project descriptions, architecture and design alternative evaluations, simulation and verification results, timing and power analysis data, and records connecting personnel to specific development projects. For more, see our page on R&D tax credit documentation.

Example Hypothetical Project

The following is a hypothetical example for illustration only. It does not represent any actual company and does not state that the work qualifies.

A semiconductor design company is developing a new processor architecture for a power-constrained application where the initial design does not meet the specified performance-per-watt target. The technical uncertainty is whether a modified pipeline architecture, an alternative clock-gating approach, and a new verification methodology can together achieve the performance, power, and coverage targets. The team develops and simulates three architecture variants with two power-management approaches, measures performance and power, and evaluates verification coverage. Based on the results, the team selects an architecture and power approach and refines the verification methodology. Records of the alternatives, simulation conditions, and results may help support analysis — but professional review is still needed.

Questions to Ask Internally

  • What specific business component was being developed or improved?
  • What technical uncertainty existed at the outset?
  • What alternatives were evaluated, and how were they tested?
  • Who performed or directly supported the work?
  • What materials were consumed in the testing?
  • How does this differ from routine design iteration?

Relationship to the Four-Part Test

The four-part test applies the same way it does in any industry. The work must be directed at developing or improving a business component (permitted purpose), must fundamentally rely on principles of the physical sciences or engineering (technological in nature), must be intended to eliminate a technical uncertainty (elimination of uncertainty), and must be conducted through a structured evaluative process (process of experimentation). Meeting one element is not enough.

Key Takeaway

Semiconductor design companies may perform activities that warrant analysis under IRC §41 — particularly work involving architectures, logic design, verification methods, and simulation. Routine design iteration does not automatically qualify. Professional review is appropriate. For related industries, see our pages on electronics manufacturing and PCB manufacturing.

Sources

  1. Internal Revenue Code §41

    Cornell Law Institute (LII)

    Section 41(d) defines qualified research and the four-part test; §41(b) defines qualified research expenses.

  2. Treasury Regulation §1.41-4

    Cornell Law Institute (LII)

    Regulatory definition of qualified research, including the process of experimentation as an evaluative process of alternatives.

  3. Instructions for Form 6765

    Internal Revenue Service

    Summarizes qualified research, excluded activities, and qualified research expense reporting.

  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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