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The One Big Beautiful Bill Act: Revitalizing U.S. R&D Tax Incentives

Within the landscape of industry innovation, Research and Experimental (R&E) expenditures remain crucial drivers of advancement and discovery. Traditionally, tax law has positioned these expenditures as a catalyst for growth, enabling businesses to deduct them and thereby alleviate taxable income. This strategic alignment underscored the importance of incentivizing domestic innovation.

The signing of the One Big Beautiful Bill Act (OBBBA) on July 4, 2025, marks a pivotal shift in the treatment of Research and Experimental expenditures. Under new Internal Revenue Code (IRC) Section 174A, businesses can once again immediately deduct their domestic R&E expenses, a critical change from the Tax Cuts and Jobs Act of 2017, which had removed this benefit.Image 3

Defining R&E Expenses - Typically, R&E (or R&D) expenses encompass costs necessary for product improvement and development, including software creation. They generally cover:

  • Wages of employees conducting research.

  • Materials and supplies in research activities.

  • Costs for external research services.

  • Overheads like rent, utilities, and repairs associated with R&E facilities.

The IRS purposefully defines these costs broadly to encourage extensive innovation across sectors.

The Historical Context - Prior to 2022, companies had discretion under Section 174 to either deduct R&E costs in the year incurred or opt for capitalization and subsequent amortization over a 60-month period. This flexibility offered notably advantageous cash flow solutions, particularly for innovation-centric enterprises.

The TCJA's 2022 amendment curbed this option, enforcing a firm requirement to amortize R&E expenses over five years for domestic research and 15 years for foreign research, consequently imposing heavier financial burdens.Image 2

Post-OBBBA Developments - With the enactment of the OBBBA effective for tax years starting after December 31, 2024, new Section 174A fundamentally shifts the expensing paradigm for domestic R&E.

Domestic vs. Foreign Applications - A key feature of the OBBBA is its differentiation based on research location:

  • Domestic R&E Expenditures: These expenses can be fully and immediately deducted, reinstating the favorable pre-2022 regime and encouraging U.S.-based research activities. Alternatively, businesses may choose capitalization if advantageous.

  • Foreign R&E Expenditures: The requirement to capitalize and amortize over 15 years persists, with prohibitions on immediate recovery of unamortized foreign R&E costs upon disposition. This stark distinction prompts multinational firms to reassess research location choices for optimal tax positioning.

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Accelerated Expensing Opportunities - The OBBBA offers a critical remedy for R&E expenses capitalized between 2022-2024 per TCJA regulations. Taxpayers with unamortized balances have several options starting in 2025 to expedite their deductions:

  • Option 1: Full Expensing in 2025: Immediate deduction of the entire remaining balance in the new tax year.

  • Option 2: Two-Year Amortization: Ratable deduction over two years, 50% in 2025 and 50% in 2026.

  • Option 3: Continue Amortization: Continual amortization over the predefined five-year term.

  • Eligible Small Businesses: These enterprises may capitalize on a potent alternative, applying retroactive expensing rules from tax years post-2021 by amending returns to seek tax refunds, provided they elect by July 4, 2026. Coordination with R&D tax credit provisions is necessary.

Strategic Interplays - The nuanced interaction of new R&E expensing rules with other tax provisions like net operating losses, bonus depreciation, and international taxation necessitates a comprehensive, strategic approach to tax planning. Modeling these interactions offers significant opportunities to manage tax liabilities and strategic planning for taxpayers.

Accounting Changes - These regulations are adopted as an automatic change in accounting method, easing compliance processes. The opportunity for a tax refund provides a direct cash flow benefit, easing previous capitalization burdens. The IRS’s Rev Proc 2025-28 clarifies making these adjustments through a return statement instead of Form 3115.

For tailored guidance, connect with our office to explore your options and devise strategies that maximize benefits while adhering to regulatory frameworks.

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