The American Taxpayer Relief Act (ATRA) revived the research credit, retroactive to 2012 and extended it through 2013. The credit equals 20% of qualified research expenses (QREs) over a “base amount,” or you can use an alternative simplified 14% credit.
For this purpose, QREs include wages spent for workers involved in research, but what about amounts paid to those workers in severance packages? According to the IRS, severance doesn’t qualify because it isn’t paid to encourage research. (IRS Legal Advice 20131102f_032813)