- Date: November 6th, 2025
- Time: 2PM EST / 1PM CST
- Length: 1 hour
- CPE: 1- Tax
From 2022 through 2024, taxpayers were required under the TCJA to capitalize and amortize research and experimental (R&E) expenditures under Section 174. The passage of the One Big Beautiful Bill Act (OB3) in July 2025 dramatically changed this landscape with the introduction of Section 174A.
In this session, we will explore how OB3 impacts the treatment of R&E expenditures, including:
- The transition from mandatory amortization to immediate expensing for domestic R&E under Section 174A.
- Continued amortization requirements for foreign R&E expenditures.
- Small business relief provisions, including retroactive application of Section 174A to tax years 2022–2024.
- Options for accelerating or spreading the deduction of previously capitalized domestic R&E.
- Procedural updates from IRS Revenue Procedure 2025-28, including automatic method change guidance.
Attendees will gain clarity on how these updates affect planning, compliance, and financial reporting, with a focus on practical applications and opportunities for taxpayers.
Learning Objectives:
- To discuss the history of and recent changes to IRC 174 and creation of 174A.
- To identify which activities and expenditures are subject to 174 and 174A treatments.
- To analyze the interplay between 174, 174A, and the R&D tax credit.
Target Audience:
CPAs, Tax Professionals, and advisors working with businesses engaged in R&D activities