Revamping R&E Tax Strategies: Insights from the One Big Beautiful Bill Act

The One Big Beautiful Bill Act (OBBBA), effective from July 4, 2025, marks a pivotal moment in tax legislation for research and experimental (R&E) expenditures. By realigning the tax treatment of these costs, the Act reinstates the immediate deductibility of domestic R&E expenditures, a longstanding incentive that was curtailed by the Tax Cuts and Jobs Act of 2017. This change is anchored in the newly introduced Internal Revenue Code (IRC) Section 174A, encouraging more U.S.-centric innovation initiatives.

Driven Research Activities

The scope of R&E expenses spans any costs associated with product development and enhancement, including software creation, which often constitute:

  • Employee wages linked to research work

  • Material and supply costs used in research

  • Outsourced research services

  • Facility-related overheads such as rent and utilities

This broad definition by the IRS ensures extensive coverage, supporting diverse innovation activities. The Transition of R&E Tax Provisions Before the TCJA reforms, businesses could elect to fully expense or amortize these costs, a flexibility that was rescinded post-2021. The OBBBA restores this critical financial relief, particularly for domestic research, permitting immediate expensing of 100% of costs in the incurred year, broadening the innovation landscape within the U.S. However, the pre-OBBBA requirement of a 15-year capitalization for foreign research remains unchanged, affecting international operational decisions. Companies might need to reassess their global strategies to optimize tax benefits.

Tax Adjustments

Options for Accelerated R&E Expensing Businesses grappling with TCJA-imposed capitalizations for 2022-2024 have several remedial solutions starting 2025:

  • Immediate Full Deduction: Offset the entire remaining balance in 2025.

  • Two-Year Amortization: Split deductions over 2025 and 2026.

  • Continued Amortization: Persist with the original five-year schedule.

  • Small Business Retroactive Expensing: Small businesses (<$31 million in three-year annual gross receipts) can retroactively apply full expensing for tax years after 2021 by submitting amended returns. This must be completed by July 2026, potentially affecting the R&D credit amount (Section 280C(c)). The IRS's provisions in Rev Proc 2025-28 simplify this transition, allowing changes via a statement on returns, eliminating the need for Form 3115.

Advisory insights from MJ Ahmed CPA PLLC, leveraging over two decades of cross-country expertise, prove indispensable. Each tax deduction choice impacts Net Operating Losses (NOL), business interest expenses, and international taxes differently. Thus, strategic modeling of all available options should guide businesses in maximizing fiscal benefits from the OBBBA reforms. Coordination with seasoned accountants ensures that the reformed R&E provisions are integrated optimally within broader tax strategies.

Strategic Business Planning

For tailored tax optimization strategies specific to your business’s needs, connect with us at MJ Ahmed CPA PLLC.

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