The simple answer is no. While the credit does not require that a taxpayer establish and maintain a contemporary time tracking system, it is important to ensure that documentation on the work being performed is being recorded regularly. If documentation of actual activities, issues, alternatives, etc. is kept, then qualifying time can be provided by Subject Matter Experts (SMEs) that have intimate knowledge about a particular project or activity.
Alex Pak is a Director at R&D Incentives Group who joined the team in 2015. His primary responsibilities include leading R&D tax credit projects including reviewing R&D activities, conducting interviews and creating documentation for defense of credits under review. His former experience includes five years of project execution and management for two tax consulting firms through which he was involved in the computation and defense of credits for a broad spectrum of companies in a wide variety of industries including engineering, manufacturing, department of defense contractors and software development firms among others.
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