R&D tax credit evidence · checked against the sources on
R&D tax credit evidence from your git history
Your git history is already a record made as the work happened, which is what the IRS and the Tax Court ask for behind an R&D credit. For the tax year, list the commits by person and by component, and mark the ones that show alternatives tried: reverts, branches never merged, spikes, benchmarks, approaches abandoned. Give your tax adviser that index with each commit's hash, and the hours or wages from your payroll records. Git cannot say how long anyone worked, and it cannot decide whether the work qualifies; your adviser applies the four-part test.
“designed to evaluate one or more alternatives”
Treas. Reg. §1.41-4 (Cornell LII) (read 9 Oct 2026)
Evidence to review with your tax adviser; not tax advice.
What git shows, and what it does not
| Your history can show | It cannot show |
|---|---|
| When each change was made, and by whom | How long anyone worked on it |
| Approaches tried and backed out (reverts) | Anyone's wages, or what they were paid for |
| Branches never merged: approaches not taken | Whether any of the work qualifies |
| What people wrote about prototypes, benchmarks and failed attempts | Uncertainty nobody wrote down |
| Which folders, packages and services the work touched | Your business components, as the tax law defines them |
Commit timestamps are written by each developer's machine. Your hosting service's record of pushes and pull requests is the stronger date, and both are records made at the time, which is what the court in George v. Commissioner asked for.
The four-part test, against what a repository holds
| IRC §41(d) asks for | What in your history may help show it |
|---|---|
| Permitted purpose: a new or improved function, performance, reliability or quality | The feature or component the commits belong to, and the pull request that says what it was for |
| Technological in nature: relies on computer science or engineering | The code itself, and the design notes beside it |
| Elimination of uncertainty about capability, method or design | Spikes, prototypes and benchmarks started before anyone knew the answer |
| Process of experimentation for substantially all of the work | Alternatives tried and compared: reverts, unmerged branches, closed pull requests, benchmark results |
Each part is judged per business component, and all four must hold. Whether they do is your adviser's call; the history is the evidence they weigh. See whether software development qualifies.
Write commits your adviser can cite
Strike Tax calls commit logs a snapshot of work in progress, and warns that messages like “updates” or “fixed this” carry nothing. Say what you tried, why the existing way would not do, and what happened, success or failure. A revert with a line on why it failed is worth more than a clean history. Squashing a branch's commits into one hides the attempts; keep the branch, or say in the squash message what was tried.
Check your own, on your machine
npx --allow-git=root github:agentwares/rd-ledger --year 2026- Fetch every branch people pushed, so the experiments that never merged are there: git fetch --all
- List the year's commits with date, hash, author and subject: git log --all --since=2026-01-01 --until=2027-01-01 --date=short --format='%ad,%h,%an,%s' > commits.csv
- Find the words people wrote while experimenting: git log --all -i -E --grep='revert|spike|experiment|prototype|benchmark|tried|abandon' --since=2026-01-01 --until=2027-01-01 --oneline
- List the branches never merged into your main branch, the approaches not taken: git branch -a --no-merged main
- Count each person's commits, and add a folder at the end to count one component: git shortlog -sn --all --since=2026-01-01 --until=2027-01-01 -- apps/router
- Give your adviser each line with its commit hash, so it can be checked against the repository, and take hours or wages from payroll, never from git.
It runs git on your repository, makes no network request and calls no LLM, and writes a dated evidence pack, evidence.md and CSVs, with each line traced to its commit. Hours and amounts appear only from figures you supply. Source (MIT)
A year-round R&D evidence ledger, kept month by month as the work happens, is not built. Each month's evidence captured that month and kept under a date we hold, so the record shows when it existed; at year end, the hours or wages you enter allocated across your business components in Form 6765 Section G's shape; and a read-only link for your tax adviser.
Not built. No price is set and nothing is charged. It gets built only if enough people ask.
Count me inSources
- Treas. Reg. §1.41-4 (Cornell LII) (read 9 Oct 2026)
- PKF O'Connor Davies: George v. Commissioner, T.C. Memo. 2026-10 (published 9 Mar 2026; read 9 Oct 2026)
- Strike Tax: how your git records can streamline R&D tax credit claims (updated 13 Aug 2026; read 9 Oct 2026)
- IRS: Instructions for Form 6765 (rev. 12/2025) (read 9 Oct 2026)