R&D Binder

At a glance

Three numbers that frame the binder before you open the PDF.

Length

11 pages

Cover plus 6 substantive sections plus appendix. Print-ready, B&W-safe, no third-party fonts. Same WeasyPrint pipeline ships every R&D Binder customer.

Scope

2 business components

The Cal.com Platform B2B Embeddable Scheduling API (92 qualifying commits) and AI-Assisted Scheduling (35 qualifying commits, Cal.ai phone, Retell, Bolna, AI translations). Both qualified independently under the four-part test.

Engineering

30 FTE estimate

Illustrative only. A real binder swaps in your payroll register and contractor invoices instead of estimates. The calculation methodology is fully disclosed inside the binder.

What is inside the binder

Six substantive sections plus a cover and a sources appendix. Each section maps to something the IRS, the new Form 6765 Section G, or your CPA will ask for.

  1. Cover and engagement summary

    Customer name, tax year, activity period, source repos, FTE estimate, and a prominent "DEMONSTRATION SAMPLE" banner so the binder cannot be mistaken for a paid engagement. Lists the rubric authority (Section 41, Section 174A, Treas. Reg. 1.41-4, Notice 2023-63, Rev. Proc. 2025-28, the December 2025 Form 6765 instructions, OBBBA / Public Law 119-21).

  2. Customer profile

    Entity type, state of incorporation, fiscal year, engineering FTE, source repository list, and a plain-English description of the qualifying activity period. This is what your CPA pastes onto Form 6765's identifying-information rows without having to translate anything.

  3. Business components

    One section per qualified business component. Each has a name, a Section 41(d)(2) component kind (computer software, in this sample), the qualifying-dimensions list (function, performance, reliability, quality), the discipline of computer-science principles applied, and a numbered list of alternatives evaluated with PR-number citations. This is the core of Section G, and it is the part Big-Four engagements charge $25k or more to draft.

  4. Four-part test analysis

    For each business component, an independent analysis of all four IRC Section 41(d)(1) parts: Permitted Purpose (Part 1), Technological in Nature (Part 2), Elimination of Uncertainty (Part 3), and Process of Experimentation (Part 4). Every claim cites a specific commit SHA or pull-request number from public GitHub history. Substantially-all (80 percent) thresholds are stated explicitly per component.

  5. Qualified Research Expense (QRE) workpaper

    Wages, supplies, computer rental (cloud compute), and contract research at the 26 U.S.C. Section 41(b)(3) 65-percent applied amount, rolled up to a total QRE figure your CPA drops directly into Form 6765 lines 5 through 9. Allocation methodology is disclosed; in a paid engagement the input is your books, not an estimate.

  6. Audit-defense flag review

    Four explicit-and-on-the-record flag analyses: foreign research (Treas. Reg. 1.41-4(c)(7) US-source rule), funded research (Section 41(d)(4)(H) operator-funded confirmation), internal-use software (whether Section 41(d)(4)(E) applies), and contract-research overweight (whether the 65-percent applied amount exceeds 50 percent of total QRE under Section 41(b)(3)). These are the four questions an examining IRS agent will probe first; the binder pre-answers them in writing.

  7. Form 6765 Section G map (appendix)

    Per-business-component table that aligns to the December 2025 Form 6765 Section G layout: Business Component Name, Type, Description, Information Sought to be Discovered, Total Wages, Total Supplies, Total Computer Rental, Total Contract Research, Total QREs. Section G is mandatory starting tax year 2026 (processing year 2027) for non-exempt filers.

  8. Sources and authority

    Every citation in the binder collected in one appendix: statute, regulations, IRS notices, IRS revenue procedures, the December 2025 Form 6765 instructions, OBBBA, plus the specific public GitHub PR numbers and commit SHAs cited in the body.

The two business components in this sample

The binder claims qualification for two distinct business components. Each is documented independently, with its own four-part-test evidence and its own row in the Section G map.

Cal.com Platform (B2B Embeddable Scheduling API)

92 qualifying commits, 2024-01-15 to 2024-12-26.

  • Kind: Computer software (Section 41(d)(2)(C)).
  • Dimensions: Function, performance, reliability, quality.
  • Discipline: Multi-tenant API design, OAuth 2.0 authorization, embeddable component architecture, schema federation, distributed billing reconciliation.
  • Sample evidence: PR #14200 (OAuth client gating for non-platform orgs), PR #14822 (platform-aware Stripe event filter), PR #15961 (platform org event-type refactor), PR #17849 (App-router migration for platform settings).

AI-Assisted Scheduling

35 qualifying commits, 2024-02-13 to 2024-12-11.

  • Kind: Computer software (Section 41(d)(2)(C)).
  • Dimensions: Function, quality.
  • Discipline: Natural-language processing, voice-AI integration, prompt-engineering for structured outputs, multi-language model translation pipelines.
  • Sample evidence: PR #14100 (Cal.ai enterprise phone calls), PR #14430 and PR #16706 (Retell webhook plus integration), PR #16828 (Bolna Voice AI), PR #16003 (Cal.ai email-assistant sunset cycle), PR #17657 (lazy-fetched AI translation backend).

Why this maps directly to Form 6765 Section G

For tax year 2026 (processing year 2027) and forward, Form 6765 Section G is mandatory for non-exempt filers. The IRS, in effect, formalized our binder's table of contents.

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).

The binder's section 3 (business components), section 4 (four-part-test analysis), section 5 (QRE workpaper), and section 7 (Section G appendix) cover all nine columns by construction. A CPA filing the return transcribes from the appendix; nothing has to be re-derived.

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.

What changes in your real binder

The Cal.com sample is a public-GitHub demonstration. Three things look different in a paid engagement.

  1. Real payroll, not an estimate. The sample assumes $180,000 fully-loaded engineering cost per FTE and a 30-FTE engineering team for illustration only. A real binder uses your payroll register, Form W-2 and Form 1099 records, and (if relevant) contractor invoices, all allocated to qualifying commits by ownership and signed off by your CPA.
  2. Your business components, not Cal.com's. The clustering pipeline runs against your repositories and surfaces your candidate components. We propose a draft list; you and your CPA confirm the scope before the binder is finalized.
  3. Real audit-defense flag answers. The sample's flag review is generic to Cal.com's public footprint. Your binder cross-references your contractor invoices for the 65-percent applied amount, your engineering org chart for the foreign-research US-source allocation, and your funding sources (operator revenue, equity, grants) for the funded-research test.

Second sample: PostHog 2024

Same pipeline, different codebase. Below is a second demonstration binder built from PostHog Inc.'s public GitHub commit history for calendar year 2024 (5,400 plus commits across the open-source posthog/posthog repository). PostHog is not an R&D Binder customer; this artifact is illustrative only.

Download PostHog 2024 sample (PDF) Open in browser

The PostHog binder identifies two business components from 2024:

  • PostHog Web Analytics (110 qualifying commits, Sep to Dec 2024): a net-new product surface with cookieless server-hash visitor identity, user-editable channel-type classification, first-class conversion goals, period-over-period query architecture, and Largest Contentful Paint scoring shipped from PR #25239 (onboarding integration) through PR #27121 (custom bounce-rate control).
  • Hog Programming Language and CDP Destinations Engine (145 qualifying commits, Aug to Dec 2024): a custom DSL with REPL (PR #24958), modules (#25796), Hog-to-JavaScript transpiler (#26143), and a destinations engine wiring Hog functions to Snapchat Pixel (#26890), Meta Ads (#26351), Brevo (#26195), Hubspot (#25920), Make (#26241), and Slack (#26667), unified through a mapping-template engine (#26866).

What this sample demonstrates that the Cal.com one does not:

  • Foreign-research caveat handling. PostHog has UK-based engineers; the audit-defense flag table explicitly excludes non-US-resident contributors from QRE per Treas. Reg. ยง 1.41-4(c)(7). The Cal.com binder dodged this caveat by picking a US-only engineering team. The PostHog binder shows the substantive treatment.
  • Programming-language as a business component. Hog is a custom DSL; the binder frames it under "computer software" with computer-science subdomains spanning programming-language design, AST construction, source-to-source compilation, and runtime telemetry. The four-part-test rubric handles novel-language work cleanly.
  • Higher commit volume per component. Cal.com's two components averaged 64 commits each. PostHog's average 128. The binder format scales without losing per-PR specificity (every claim cites a numbered PR).

Next steps

If either binder reads like the artifact you want for your own company, two paths.

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