Learning Center
We keep you up to date on the latest tax changes and news in the industry.

Revitalizing R&E Tax Benefits with the OBBBA

The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, marks a significant pivot in the treatment of Research and Experimental (R&E) expenditures, a cornerstone of innovation across industries. This reform has reshaped tax strategies by reintroducing the option for businesses to immediately deduct domestic R&E expenses, revoking a notable change imposed by the Tax Cuts and Jobs Act of 2017.

Under the new Internal Revenue Code Section 174A, the OBBBA not only restores the immediate deduction capability but also enforces stringent capitalization requirements for foreign R&E activities. This legislative adjustment is pivotal for U.S.-based innovation, enabling businesses to reap immediate tax benefits and sustain competitive growth.

Understanding R&E Expenditures

R&E expenditures, often called R&D costs, are broad categories defined by expenses related to developing or improving products, including software. These generally encompass:

  • Employee wages dedicated to research activities.

  • Materials and supplies consumed during research.

  • Costs for subcontracted third-party research services.

  • Overhead costs linked to facilities and equipment used in R&E, such as rent and utilities.

The IRS’s broad definition aims to catalyze a wide range of innovative undertakings.

A Brief History of R&E Expensing

Before the TCJA, businesses had the flexibility to either deduct R&E expenses in the year incurred or amortize them over a minimum of 60 months. This proved beneficial for companies focusing heavily on innovation. Post-2017, however, all R&E expenditures required capitalization and amortization over five years for domestic research and 15 years for foreign research, intensifying cash tax obligations, particularly for startups.

The Impact of the OBBBA on R&E Deductions

Effective from the 2025 tax year, Section 174A revitalizes the landscape for domestic R&E:

  • Domestic R&E Expenditures: Companies can now permanently deduct 100% of domestic costs in the year they are incurred, reinstating pre-2022 policies and supporting local research initiatives.

  • Foreign R&E Expenditures: The requirement for 15-year capitalization on international research costs remains unchanged. This significant disparity could prompt multinationals to reconsider their research locales to harness tax efficiencies.

Image 3

Options for Accelerating Previously Amortized Expenses

The OBBBA offers transition relief for R&E expenses originally capitalized from 2022 to 2024, presenting taxpayers with choices starting in 2025:

  • Full Expensing in 2025: Deduct the total unamortized balance of domestic R&E costs within the year.

  • Two-Year Amortization: Disburse deductions over two years, splitting the balance equally across 2025 and 2026.

  • Continued Amortization: Elect to maintain the original five-year amortization schedule.

  • Small Business Expensing: Eligible small businesses, defined as those with average annual gross receipts of $31 million or less, may retroactively apply full expensing rules back to 2022 by amending prior returns.

Interplay with Broader Tax Provisions

The revised R&E expensing rules intertwine with other tax aspects, including NOL and bonus depreciation, and international taxation for larger enterprises. Comprehensive assessment of these provisions is crucial for optimizing tax strategies, enhancing cash flow, and minimizing liabilities.

Transitioning Accounting Methods

These changes are deemed an automatic accounting method adjustment, streamlining compliance. IRS guidance via Rev Proc 2025-28 allows for method transition by attaching a statement to returns. Image 1

For tailored advice and modeling of strategic options, contact our office today to ensure you maximize all available benefits under these revamped tax provisions.

Share this article...

Want tax & bookkeeping tips and insights?

Sign up for our newsletter.

I confirm this is a service inquiry and not an advertising message or solicitation. By clicking “Submit”, I acknowledge and agree to the creation of an account and to the and .
Shelton Financial Management LLC We love to chat!
Please feel free to use the buttons below to use our Ai powered chat assistant or contact us.
Please fill out the form and our team will get back to you shortly The form was sent successfully