Yes, there is an alternative method to identify individuals who performed each research activity. Instead of providing the first and last names of each person, a taxpayer may identify the individuals by listing their titles or positions. This information can be aggregated, but it must specify the exact number of individuals and each individual's title or position. However, taxpayers should be aware that they may be asked to provide specific names upon substantive review of the claim.
Sources:
§ 1.41-4. Qualified research for expenditures paid or incurred in taxable years ending on or after December 31, 2003.
FAA 20214101F
Using the New Guidance for Research Credit Substantiation
T.D. 8930
Navigating the Shifting Landscape of Research Credit Audits
