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Revamping R&E Tax Strategies: Insights Post-OBBBA 2025

Research and Experimental (R&E) expenditures lie at the heart of innovation across diverse sectors. These costs, historically incentivized through tax deductions, propel business growth by easing taxable income burdens.

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The enactment of the One Big Beautiful Bill Act (OBBBA) on July 4, 2025, marked a pivotal shift in how businesses can handle domestic R&E expenditures, effectively reversing restrictive measures imposed by the Tax Cuts and Jobs Act (TCJA) of 2017. Under the reinstated provisions of IRC Section 174A, companies can now immediately deduct domestic R&E costs, positioning the U.S. as a leader in fostering innovation, albeit with more stringent rules for international research initiatives.

Understanding R&E Costs

Generally termed as R&D expenses, R&E costs encompass those incurred for product development and improvement, including software creation. Key expenditures often include:

  • Salaries for personnel involved in research activities.

  • Material and supply costs directly consumed in research.

  • Expenses paid to contractors for research services.

  • Various overhead costs like facility rent, utilities, and insurance attributed to the research process.

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This broad definition by the IRS encourages expansive innovation efforts.

Historical Context and Changes

Before the TCJA took effect post-2021, businesses could choose between immediate expensing or capitalizing and amortizing R&E costs over a minimum of 60 months under the former Section 174. However, TCJA mandated amortization, spreading deductions over five years domestically and 15 years for foreign research, which adversely affected cash flows for emerging tech and startup companies with significant R&E investments.

Post-OBBBA: A Revised Landscape

Effective for tax years commencing after 2024, the OBBBA introduces fundamental shifts:

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  • Domestic R&E Expenditures: Immediate deduction of these costs is reinstated, offering a renewed financial edge for U.S.-based innovation. Businesses may also choose to amortize over 60 months.
  • International R&E Activities: The pre-existing 15-year amortization framework remains, compelling multinationals to reassess their strategic placement of research facilities.
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Navigating Transitional Relief

To ease prior capitalization burdens, the OBBBA offers taxpayers the following solutions:

  • Full Expense in 2025: Deduct remaining unamortized domestic costs within the first post-2024 tax year.
  • Two-Year Amortization: Spread the deduction of remaining costs equally across 2025 and 2026.
  • Continue Original Amortization: Maintain the five-year amortization schedule for ongoing consistency.
  • Retroactive Expensing for Small Businesses: Eligible small businesses can amend previous years' returns to reclaim taxes paid prior to the Act’s enactment.

Interrelation with Broader Fiscal Policies

These R&E adjustments correlate dramatically with various segments of the tax code, including net operating loss (NOL) policies, bonus depreciation, and international tax considerations, forming a comprehensive picture. Taxpayers should strategically forecast outcomes, integrating these tax benefits with overarching fiscal strategies to optimize liability reductions.

Accounting Method Adjustments

This shift is designated as an automatic change in accounting method for simplification, allowing firms to reconcile these deductions with ease, thereby enhancing liquidity. For procedural guidance, professionals can refer to Rev Proc 2025-28 for efficient returns' amendment processes.

For personalized strategic planning under the OBBBA’s provisions, connect with our office at Sullivan & Company CPA Inc. and explore tailored solutions that align with your business objectives.

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Our team specializes in estate, gift, valuation, and forensic accounting matters. Book a confidential consultation to discuss your needs and get clear, actionable strategies.
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