
Author:
R&D Tax Advisors
Role:
CPAs
Publish Date:
Jan 21, 2026
The Question
Most people focus on the last three words: research activities.
Very few pause on the first one: increasing.
That omission is the root of a lot of confusion — and more than a few bad R&D credit outcomes.
The Short Answer
The R&D credit is not designed to reward doing R&D.
It is designed to reward doing more R&D over time.
That concept is built directly into the statute, the calculations, and the way the credit scales year over year.
Ignoring the “increasing” part leads to:
unrealistic expectations,
misinterpretation of credit amounts,
and frustration when results don’t match assumptions.
Why the Credit Was Structured This Way
At its core, the R&D credit is an incentive — not a reimbursement.
Congress designed it to encourage companies to:
expand technical effort,
take on more uncertainty,
and invest progressively in innovation.
That’s why the credit compares current-year qualified research expenses to some form of historical baseline.
The baseline matters because growth matters.
What “Increasing” Looks Like in Practice
“Increasing” does not mean:
every year must be larger than the last,
or that a single down year eliminates future credits.
It does mean that:
historical spending affects current results,
methodology choices compound over time,
and base-year treatment has long-term consequences.
Two companies with identical current-year R&D spend can generate very different credits depending on their past.
That’s not a bug — it’s the point.
Why This Trips Companies Up
This concept is often overlooked because:
early discussions focus on eligibility, not mechanics,
providers emphasize upside without explaining baselines,
and companies assume credits scale linearly with spend.
They don’t.
Understanding the “increasing” aspect is what separates:
one-time credit chasing
fromsustainable, systemized R&D strategies.
Why This Matters for Long-Term Planning
Once companies understand this, a few things change:
they stop treating R&D credits as transactional,
they care more about consistency than spikes,
and they think harder about documentation and methodology.
This is also why poorly constructed first-year studies can haunt future years — and why thoughtful ones compound value.
The Takeaway
The R&D credit rewards growth, not just activity.
The word increasing isn’t marketing language. It’s the organizing principle behind the entire credit.
Companies that understand that early:
set better expectations,
make better methodological decisions,
and get more durable value over time.
Those that ignore it often spend years trying to unwind early assumptions.



