What is a business component for the R&D tax credit?
A business component (IRC §41(d)(2)(B)) is any product, process, computer software, technique, formula, or invention a company develops or improves and either holds for sale, lease, or license, or uses in its business. It is the unit of analysis for the R&D credit: you must show that each business component independently satisfies the four-part test.
Identify components at a meaningful level — a product feature, process improvement, or software module — not so broad that one component covers all of your R&D, and not so granular that every code change becomes its own. For each component, keep documentation of the permitted purpose, the technical uncertainty at the outset, and the process of experimentation used to resolve it. Beginning with 2026 tax years, Form 6765 Section G requires business-component-level detail.
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What Is a Business Component?
Under IRC §41(d)(2)(B), a "business component" is any product, process, computer software, technique, formula, or invention which is to be:
- Held for sale, lease, or license, or
- Used by the taxpayer in a trade or business
The business component is the unit of analysis for the R&D credit. For each business component, the taxpayer must be able to demonstrate that qualifying research activities were conducted — meaning that each of the four prongs of the four-part test was satisfied.
Identifying Business Components
During the MainStreet study, your Subject Matter Expert (SME) will work through your R&D activities to identify each distinct business component. Consider the following questions:
What were you trying to build or improve?
List each distinct product, feature, process, or software module that your team worked on during the tax year. Think in terms of project names, sprint goals, product roadmap items, or engineering tickets.
Was there a specific technical challenge?
For each item on your list, ask whether there was a genuine technical uncertainty at the outset — something your team didn't know could be done, or didn't know how to do. If yes, it may be a business component.
Did your team experiment to find a solution?
Was there a process of trial and error — testing alternatives, iterating on designs, running experiments? If your engineers simply implemented a known solution, that activity may not qualify.
Did the work have a permitted purpose?
Was the goal to improve functionality, performance, reliability, or quality? Routine maintenance, bug fixes with known solutions, and cosmetic changes typically don't qualify.
Documentation Requirements for Each Business Component
For each business component, you need documentation that walks the IRS through the four-part test. This doesn't require elaborate reports — the goal is to show contemporaneous evidence that qualifying research was actually conducted.
Permitted Purpose Documentation
- Project brief or charter describing the intended improvement
- Product requirements or design specification document
- SME statement describing the goal of the project
- Feature or epic ticket descriptions (Jira, Linear, GitHub Issues, etc.)
Technical Uncertainty Documentation
- Meeting notes documenting the technical challenge or unknown
- Design alternatives considered at the start of the project
- Engineering post-mortems that discuss what was tried and failed
- Architectural decision records (ADRs) documenting uncertainty
Process of Experimentation Documentation
- Sprint retrospectives and iteration logs
- Test results and performance benchmark comparisons
- A/B test designs and results
- Code review comments discussing alternative approaches
- Design revision histories (Figma version history, etc.)
Technological in Nature Documentation
- Technical specifications, architecture diagrams, or design documents
- Evidence the work relied on engineering, computer science, or a hard science
- Links to relevant technical research, papers, or frameworks consulted
Examples by Industry
| Industry | Example Business Component | Typical Technical Uncertainty |
|---|---|---|
| Software / SaaS | New data processing pipeline | Whether real-time throughput targets could be achieved at scale with chosen architecture |
| Software / SaaS | Machine learning recommendation engine | Whether the model could achieve accuracy thresholds using available training data |
| Manufacturing | New material formulation | Whether the material could meet tensile strength specs without exceeding cost targets |
| Engineering / Construction | Custom structural system for unusual site conditions | Whether the proposed design approach could meet code requirements for the specific load conditions |
| Life Sciences | Novel drug delivery mechanism | Whether the delivery method could achieve the target bioavailability profile |
| Clean Energy | Battery management algorithm | Whether the algorithm could optimize charge cycles while maintaining safety margins |
The Subject Matter Expert Role
A Subject Matter Expert (SME) is a technical employee with firsthand knowledge of the company's R&D work — typically an engineer, scientist, or technical lead. The SME plays a critical role in the MainStreet study process:
- Reviews each employee's job duties and certifies the percentage of time spent on qualifying research activities
- Identifies and certifies the qualifying business components for the tax year
- Provides descriptions of the technical uncertainty and process of experimentation for each component
- Signs the SME certification that becomes part of the IRS-ready package
