The One Big Beautiful Bill Act (OBBBA) reestablishes same-year deductions for domestic research expenses beginning in 2025. Under new IRC §174A, U.S. companies can fully expense qualified R&D costs immediately, significantly improving the cash flow benefits of innovation investments. Foreign research, however, remains subject to 15-year amortization. Optional 60-month amortization...

The “One, Big, Beautiful Bill" promises to provide one big deduction for R&D expenditures. Section 111002 aims to provide immediate relief for businesses engaged in research and development activities within the United States. This marks the most promising proposal to walk back the R&D expenditure amortization requirements since they went...

The IRS recently announced several notable changes to the process of claiming the R&D Tax Credit, announcing welcome reductions to requirements for filing amended R&D Credit claims and reduced requirements for the proposed Form 6765. In response to feedback, the IRS has revised the draft Form 6765 and has also waived...

The recent MBJ v. Commissioner ruling highlights the important role of contract language in determining eligibility for Research and Development (R&D) Credits. MBJ, a structural engineering firm, had $190,000 in credits disallowed due to inadequate contract language. Although MBJ's contracts allowed for phase inspections and termination for substantial failure to...

A recent Tax Court ruling in S Moore v. Commissioner serves as a reminder of the important role documentation plays in supporting claims for research credits. In this case, the Tax Court disallowed a tax credit for research expenses claimed by a married couple due to inadequate documentation...

On Thursday, March 21, the Senate Finance Committee held a hearing on the Biden 2025 Budget Proposal, questioning Treasury Secretary Janet Yellen on various aspects of the proposed budget, with many members noting concern about the proposed increase of the corporate tax rate and aspects of the budget that would...

The proposed Tax Relief for American Families and Workers Act of 2024 changes the period for when companies must start the five-year period for the deduction of research and experimental expenditures from tax years beginning after December 31, 2021, to tax years beginning after December 31, 2025...

On September 8, 2023, the Internal Revenue Service (“IRS”) and Department of the Treasury (“Treasury”) released an advance version of Notice 2023-63. This Notice provides interim guidance intended to clarify the amortization and capitalization of specified research and experimental (“SRE”) expenditures under Section 174, amended by the Tax Cuts and Jobs...

An Internal Revenue Service new release previews proposed changes to certain sections of Form 6765, Credit for Increasing Research Activities, commonly known as the Research & Development (R&D) tax credit. The IRS is soliciting feedback in the absence of the formal draft release process for form changes. The...