The three steps

The same three steps that the apex page summarizes, with the technical and legal detail that matters for your CPA's review.

  1. Connect your codebase

    Read-only OAuth installation of the R&D Binder GitHub App on your organization. We pull commit metadata (SHA, author, date, message, file paths, lines added or removed) and pull-request titles for the qualifying tax year. We do not pull source code by default; if you opt in we can read README and ARCHITECTURE files for component-naming context only. We never write to your repos and never push commits.

  2. Cluster and analyze

    Commits cluster into Section 41(d)(2) business components using a combination of Conventional Commits scope tags, file-path heuristics, and pull-request title keyword frequency. Each candidate component is then scored against the four-part test from 26 U.S.C. Section 41(d)(1) and Treas. Reg. 1.41-4: Permitted Purpose, Technological in Nature, Elimination of Uncertainty, and Process of Experimentation. Every claim cites a specific commit SHA or PR number; nothing is paraphrased.

  3. Deliver the binder

    You receive a PDF binder (the same format as the Cal.com 2024 sample) plus a QRE workpaper allocating wages, supplies, computer rental, and contract research at the Section 41(b)(3) 65 percent applied amount, plus a Form 6765 Section G appendix mapped column-for-column to the December 2025 IRS layout. Your CPA reviews, asks questions, files Form 6765. We never sign the return.

What we read, what we never touch

Read-only access only. We do not need write access, admin access, or production credentials. The scope is the minimum required to assemble contemporaneous documentation.

What we read

  • Commit metadata: SHA, author, date, message, parent SHAs.
  • File paths and line-count deltas (not file contents).
  • Pull-request titles, descriptions, and merge metadata.
  • Branch and tag names.
  • Optional: README, ARCHITECTURE, ADR, and design-doc files for component-naming context (opt-in).
  • Customer-supplied: payroll register, contractor invoices, supplies and cloud-compute cost summaries (encrypted upload, single-engagement retention).

What we never touch

  • Source code file contents (unless you explicitly opt in for design-doc reads).
  • Production environment variables, secrets, or credentials.
  • Customer or end-user personally identifiable information (PII).
  • Customer billing, financial, or revenue data outside the QRE inputs you provide.
  • Your CI/CD pipelines, deployment artifacts, or production logs.
  • Any system that would touch the live product.

The four-part-test rubric, in plain English

IRC Section 41(d)(1) requires every qualifying business component to satisfy four independent tests. The binder scores each component against all four, with cited evidence per claim.

  1. Permitted Purpose (Section 41(d)(1)(B)(i)): the activity must be intended to discover information that is technological in nature and that relates to a new or improved business component along at least one of these dimensions: function, performance, reliability, or quality. We map each commit cluster to one or more of these four dimensions with PR-number evidence.
  2. Technological in Nature (Section 41(d)(1)(B)(ii)): the activity must rely on principles of computer science, engineering, biology, chemistry, or physics. For software, we cite the specific computer-science subdomains involved (multi-tenant authorization, distributed-systems consistency, machine-learning pipelines, vendor-adapter design, etc.) and the technical approach selected.
  3. Elimination of Uncertainty (Section 41(d)(1)(A)): the activity must be undertaken to eliminate uncertainty about the capability, methodology, or design of a business component. We surface the specific open questions documented at the start of the qualifying period and the commits or PR threads that resolved them.
  4. Process of Experimentation (Section 41(d)(1)(C)): the activity must constitute a process of experimentation in which two or more alternatives were evaluated and the selection involved iteration. We cite specific PR numbers showing alternatives evaluated, decisions made, refinements iterated, and reverts.

The binder also enforces the substantially-all rule from Treas. Reg. 1.41-4(a)(6): at least 80 percent of the activities in a claimed business component must constitute elements of a process of experimentation. Documentation, lint-only, and cosmetic-copy commits are categorized separately and excluded from QRE.

Form 6765 Section G compliance, by construction

Starting tax year 2026 (processing year 2027), Section G of Form 6765 is mandatory for non-exempt filers. The binder produces exactly what Section G requires.

Section G requires per-business-component reporting along nine columns: Business Component Name, Business Component Type (product, process, computer software, technique, formula, or invention), Business Component Description, Information Sought to be Discovered, Total Wages for Qualified Services, Total Cost of Supplies, Total Computer Rental, Total Applicable Amount of Contract Research, and Total Qualified Research Expenses (QREs).

Every R&D Binder includes a Section G appendix that maps to those nine columns one-to-one. The narrative sections of the binder produce the description and information-sought rows; the QRE workpaper produces the wages, supplies, computer rental, and contract research rows. Your CPA transcribes from the appendix; nothing has to be re-derived at filing time.

Qualified Small Businesses (under $5M in gross receipts and less than 5 years of gross-receipts history) electing the Section 41(h) payroll-tax offset are exempt from Section G reporting, capped at $500,000 per year against employer FICA. We still produce the Section G map for QSB customers so it is on file the day the company outgrows the carve-out.

Timeline: 2 to 3 weeks, end to end

Five phases. Most of the work is on our side. You spend roughly 2 to 4 hours total across the engagement, spread across async questionnaires and document reviews.

  1. Day 1 to 2: kickoff and ingest

    You install the R&D Binder GitHub App (5 minutes) and complete a short kickoff questionnaire (typically 10 to 15 minutes). We pull commit history, PRs, and any opt-in design docs, and produce a draft cluster list of candidate business components.

  2. Day 3 to 5: scoping conversation

    You and your CPA review the candidate component list async - we share it as a comment-ready document. We finalize the scope: which components are in, which are out, and the qualifying date range per component. Scope is locked here; later changes incur scope-change fees.

  3. Day 6 to 12: drafting

    We score each component against the four-part test, build the QRE workpaper from your payroll register and contractor invoices, run the audit-defense flag review, and assemble the binder. No customer time required during this phase.

  4. Day 13 to 16: customer review

    Draft binder delivered as a comment-ready document. You and your CPA flag corrections, additions, and clarifications in writing. We turn revisions in 2 business days.

  5. Day 17 to 21: finalization

    Final binder PDF, final QRE workpaper, final Section G appendix, and the source-citation index delivered. Your CPA files Form 6765 with the binder attached as the contemporaneous workpaper.

What we need from you

Five things. Most are exports your finance or HR system already produces.

  1. GitHub OAuth installation for the R&D Binder GitHub App on your engineering organization. Read-only scope, revocable any time.
  2. Payroll register export for the qualifying tax year, in CSV or PDF, showing employee name, role, start and end dates, and total annual fully-loaded compensation. We use this to allocate wages to qualifying activity.
  3. Contractor invoices or 1099 summary for engineering contractors active during the qualifying year. We apply the Section 41(b)(3) 65 percent applied amount.
  4. Cloud-compute and supplies cost summary (optional but typically adds 10 to 30 percent more QRE for SaaS): AWS, GCP, Azure, Vercel, Cloudflare, etc., for the qualifying year, plus any qualifying physical supplies.
  5. Your CPA's contact so we can answer their review questions directly without round-tripping through you.

Ready to see the numbers

Two short next steps.