The One Big, Beautiful Bill Act reinstates immediate expensing of domestic research expenses, reducing the tax burden and incentivizing reinvestment in U.S.-based research and development including software development across a wide range of industries. In this context, accurate and defensible estimation of qualified research expenses (QREs) is of high importance. Statistical sampling provides a practical framework for estimating QREs for a well-defined population of business components (sampling frame) documented in accordance with Internal Revenue Code Section 41 (Form 6765). IRS Revenue Procedure 2011-42 permits both attribute and variable statistical methods, although the latter (stratified mean and difference estimators) are often regarded as the standard approach to QRE estimation. In this paper, we compare attribute and variable statistical methods within a simulation study and demonstrate that attribute methods offer several theoretical and practical advantages. A key concern with the simple attribute estimator is the possibility of upward bias in QRE determination arising from a preponderance of high potential QRE (pQRE), non-qualified projects in the sampling frame. We address this concern by introducing a stratified sampling design that ensures adequate representation of high pQRE projects in the sample. We demonstrate that a convolution-based stratified attribute estimator produces a valid one-sided 95% lower confidence bound on total QREs across a range of sampling frame structures.
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