An owner's salary is not wholly qualified simply because the owner oversees product development. Qualified services and their time allocation must be established. Section 41's substantially-all rule can affect wage inclusion when its requirements are actually met, but a title or unsupported percentage is not enough.

A specific business-owner situation

A founder handles sales, fundraising and technical supervision. A study includes the full salary without distinguishing technical research supervision from general executive work.

Illustrative example, not a client result.

What to establish before filing

  1. Map duties to qualifying research services.
  2. Substantiate time spent on each category.
  3. Test any substantially-all treatment using actual evidence.

Which fact changes the answer?

Direct supervision of qualifying experimentation differs from executive oversight of the whole company. The statutory threshold cannot be assumed from a technical background.

A mistake to avoid

General company management is not automatically direct research supervision.

Records that support the decision

  • Calendar and project records.
  • Role descriptions.
  • Payroll and allocation workpaper.

The decision to document

Record the included wage amount and the service evidence supporting it, including any threshold relied upon.

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Sources and editorial context

General educational information prepared with AI assistance. No individual professional review is claimed. Apply the relevant tax-year rules to the actual records. Editorial policy · AI disclosure.

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