How OBBBA Revolutionizes R&D Tax Benefits

Research and Experimental (R&E) expenses are vital in stimulating innovation across multiple sectors. Traditionally, tax treatment of these expenses has encouraged innovation by allowing deductions that lower taxable income.

The One Big Beautiful Bill Act (OBBBA), enacted on July 4, 2025, restores the immediate deduction of domestic Research and Experimental expenses, reversing the stringent amendments of Tax Cuts and Jobs Act (TCJA) of 2017. This pivotal legislation, incorporated in Internal Revenue Code (IRC) Section 174A, reinstates significant incentives for American innovation, albeit with strict capitalization requirements for international R&E activities.

Understanding R&E Expenses

Commonly referred to as R&D costs, these expenditures are linked to the enhancement or creation of new products, including software. Typical expenses encompass:

  • Salaries for research-focused personnel.

  • Materials and supplies used during research.

  • Contractor fees for outsourced research services.

  • Overhead costs, such as rent, utilities, insurance, and repairs related to R&E efforts.

The IRS defines these costs expansively to support a broad range of innovative efforts.

Image 1 R&E Financial Impacts Pre and Post-OBBBA

Prior to TCJA adjustments effective after December 31, 2021, businesses could either deduct R&E expenses immediately or amortize them over at least 60 months under old Section 174, offering substantial cash flow advantages for innovation-driven firms.

Post-OBBBA, effective for tax years starting January 1, 2025, IRC Section 174A dramatically shifts dynamics for domestic R&E.

Delineation Between Domestic and Foreign Research
  • Domestic R&E Expenditures: Businesses can fully deduct 100% of these expenses immediately, reinstating pre-2022 favorable conditions, thus strongly motivating domestic research. Companies may opt to amortize these costs over at least 60 months if preferred.
  • International R&E Expenditures: The 15-year capitalizing rule stays. Immediate recovery of unamortized bases on foreign R&E post-May 12, 2025, is prohibited, prompting global enterprises to rethink research geographies for tax advantage.

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Streamlined Expense Acceleration for Existing Amortizations

The OBBBA allows transition relief for capitalized R&E expenses during the 2022-2024 period:

  • Option 1: Full Expensing for 2025: Deduct the entire remaining unamortized domestic R&E balance in the first tax year post-2024.
  • Option 2: Two-Year Amortization: Spread deductions (50% in 2025 and 50% in 2026).
  • Option 3: Continue Original Amortization: Option to keep amortizing over the five-year schedule.
  • For Small Businesses: Eligible small companies can retroactively apply full expensing by amending returns for 2022, 2023, and 2024 to seek refunds, coordinated with R&D tax credit adjustments by July 4, 2026.
Image 2 Integration With Broader Taxation Elements

These R&E deductions engage with other Tax Code sections, such as net operating loss (NOL) rules, bonus depreciation, interest expense limitations, and international tax obligations for major enterprises. Thorough evaluation of these elements is advisable, integrating new deductions with other available tax reliefs possible in 2025. Such comprehensive planning offers strategic tax reduction opportunities.

Accounting Method Evolution - Treated as an automatic accounting method change, simplifying compliance further. The provision for deduction catch-up offers significant capital influx, relieving businesses from previous capitalization stress. The IRS offers guidance on the seamless method change without Form 3115 filing.

For tailored modeling of options and strategies unique to your needs, to understand impacts such as NOL rules and interests expense deductions, contact us for detailed insights.

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