Credit for increasing research activities
A credit against tax for research spending above a firm's historical base.
JCT line: "Credit for increasing research activities", corporate ($32.1B) plus individual ($1.0B). Rises to $42.6B by FY2029, the largest sustained increase of any item in this dataset.
The credit is incremental, computed against a firm's own historical base, which rewards sustained large research programmes over occasional ones. Qualification also turns on contemporaneous documentation of qualifying activity, a compliance capability that scales with size. Claims are dominated by a small number of very large corporate filers.
Structural reading
The purest example on this list of an expiry date operating as a recurring appointment. The credit was enacted in 1981 with a five-year sunset and was then extended on a short-term basis again and again for roughly three decades before being made permanent in 2015. Each extension was a separate occasion on which an organised beneficiary class had to be attended to and a diffuse public did not, which is the mechanism §199A has now been through once. It is also the fastest-growing item in this dataset, rising to $42.6B by FY2029. The structural point is not that research should go unsupported, but that an incremental credit measured against a firm's own history rewards scale and continuity rather than discovery, and that the boundary defining qualifying activity is contested precisely because so much money turns on it.
Who gets it
The channels the benefit actually flows through, described by asset position, entity form and form of return. Never by named individuals.
Cost split by the concentration score. That score is a judgement rather than a published figure, so treat this as the scale of the split, not an audited allocation.
- Large firms with sustained research programmes
Because the credit applies to spending above a base, a firm that researches continuously earns it year after year, while one that researches intermittently often falls below its own base and earns nothing.
- Entities able to document qualifying activity
Claiming the credit requires contemporaneous records showing that specific work met the statutory four-part test. That documentation function is a fixed cost, which favours firms large enough to staff it.
- The advisory industry built on the boundary
What separates creditable research from routine engineering is contested and lucrative, sustaining a specialist practice whose fees are a benefit distinct from anything reaching a laboratory.
Who pays
General taxpayers, and firms whose research is too small, too irregular or too poorly documented to qualify.
This transfer follows a general pattern, asymmetric organisation, sustained expert attention, and scheduled expiry dates.
How rent-seeking works →Legislative history and accountability
Enacting statutes, major amendments, recorded votes with party breakdown, and live reform proposals.
Enabling legislation
- Economic Recovery Tax Act of 1981P.L. 97-34Aug 13, 1981
Created the credit as an explicitly temporary measure, scheduled to expire after five years.
Mixed coalitionEnacted by a Republican president with a Democratic House, passing with support from a bloc of the majority party alongside the minority. No separate roll call on this provision is recorded here.
Major amendment
- Protecting Americans from Tax Hikes Act of 2015P.L. 114-113Dec 18, 2015
Made the credit permanent after roughly three decades of short-term extensions, and allowed smaller firms to claim it against payroll tax. Enacted within a bipartisan year-end package.
BipartisanPassed with large majorities from both parties as part of a year-end appropriations and tax package. No separate roll call on this provision is recorded here.
Sources and data freshness
Published within the last year. Figures marked unverified are seed estimates that have not been reconciled line-by-line against the primary source document. See the methodology for how each score is constructed.