There's a contract setup where neither the firm doing the research nor the client paying for it can claim the R&D tax credit.
David Wiener explains the combination: the firm keeps no rights in the research, and it only gets paid if the research succeeds. The client didn't carry the risk and the firm didn't keep the rights, so the regulations say neither side can treat any of the costs as qualified research expenses.
From The Tax Strategy Playbook.
Full episode: https://taxstrategyplaybook.com
No-cost analysis through CSSI: https://calendly.com/david-wiener/cs or 770-224-8504, option two
This is educational content, not tax advice for your situation. Talk to your tax professional.