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Advisory: credits and decisions in Michigan

Michigan’s refundable R&D credit, new for 2025, pays even pre-revenue companies; the rest of the advisory work is the Section 174 decoupling and 24 city income taxes.

Jurisdiction
Michigan
Reading time
2 min
Checked
October 12, 2026
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Key figures

Michigan advisory

2026, with sources

R&D credit
RefundableAvailable to CIT filers and withholding tax filers, for tax years beginning on or after Jan 1, 2025.
R&D credit basis
MQREs over baseMichigan qualified research expenses above a base amount, during the calendar year claimed.
Section 174 for Michigan
AmortizedDomestic R&E is amortized over five years for Michigan income taxes.
Reciprocity
IL, IN, KY, MN, OH, WIMichigan employers don’t withhold Michigan tax from residents of these states.
Cities with income tax
24Detroit’s is administered by the Michigan Treasury; the others run their own.

A refundable R&D credit, and a decoupled Section 174

Michigan brought back a research and development credit for tax years beginning on or after January 1, 2025, under Public Acts 186 and 187 of 2024. It is computed on Michigan qualified research expenses above a base amount, is available to CIT filers and to flow-through businesses through withholding tax, and is refundable — so a loss-making company can receive it as cash. Treasury caps the credit by business size and in aggregate statewide, prorating claims when they exceed the cap; Revenue Administrative Bulletin 2026-4 sets out the mechanics.

The same companies need to know that Michigan did not follow the federal return to immediate R&D expensing. The credit and the deduction move in opposite directions: Michigan pays you for research while taxing more of it in the year it’s spent.

Remote hires and city taxes

Twenty-four Michigan cities levy income taxes. Detroit’s — administered by the Michigan Department of Treasury — taxes residents at 2.4% and nonresidents working in the city at 1.2%, and also has its own corporate income tax. The other 23 cities, including Grand Rapids, Lansing, Flint and Saginaw, administer their own. A company with one employee who lives or works in one of those cities can owe city withholding and a city return.

At the state level, Michigan has reciprocity with Illinois, Indiana, Kentucky, Minnesota, Ohio and Wisconsin, so an employee commuting in from any of them is taxed by their home state. Reciprocity doesn’t extend to city taxes.

Where founders go wrong in Michigan

Most Michigan surprises are about divergence from the federal return and about cities.

  • Copying the federal Section 174A deduction onto the Michigan return.
  • Missing city withholding because the employee lives in a taxing city the company has never heard of.
  • Assuming ESTA doesn’t apply to a three-person company; it applies to every Michigan employer.
  • Not filing a CIT return in a loss year, and so not establishing the Michigan business loss carryforward.
  • Leaving the refundable R&D credit unclaimed because the company has no Michigan tax to offset.

Common questions

Can a pre-revenue startup get cash from Michigan’s R&D credit?

Yes, which is unusual. Michigan’s R&D credit, available for tax years beginning on or after January 1, 2025, is refundable, and it can be claimed by CIT filers and by flow-through businesses against withholding tax. The credit is computed on Michigan qualified research expenses above a base amount; Treasury’s Revenue Administrative Bulletin 2026-4 explains the calculation, and the claim is filed through Michigan Treasury Online.

Does Michigan follow the federal QSBS exclusion?

Michigan’s individual income tax starts from federal adjusted gross income, and Treasury’s February 2026 decoupling notice does not list Section 1202 among the provisions Michigan adjusts. Founders should confirm with their own preparer, but the default is that federal QSBS treatment flows through.

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Sources

Checked against each agency’s own page on . Rates and thresholds change, usually on January 1.

General information for US companies, not tax, legal or accounting advice for yours. Rules and thresholds change; confirm the specifics with a CPA or the agency before you act on them.

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