News & Analysis as of

Internal Revenue Code (IRC) Research and Development Tax Deductions

Cooley LLP

The ‘One Big Beautiful Bill Act’ Permits Immediate Deduction of Domestic R&E Expenditures, in Some Cases Retroactively

Cooley LLP on

On July 4, the “One Big Beautiful Bill Act” (OBBBA) was signed into law, which includes provisions restoring immediate deduction of domestic research and experimentation (R&E) expenditures in tax years beginning after...more

Ballard Spahr LLP

Initial Insights Into the One Big Beautiful Bill: Key Provisions for Private Equity Funds and Fund Sponsors

Ballard Spahr LLP on

Recently, President Donald Trump signed the bill known as the One Big Beautiful Bill Act (OBBBA) into law. OBBBA permanently extends many provisions of the Internal Revenue Code (Code) introduced by the Tax Cuts and Jobs Act...more

Williams Mullen

Implications of the One Big Beautiful Bill Act on Tax Deductions for Businesses

Williams Mullen on

President Trump signed the One Big Beautiful Bill Act (OBBB Act) into law on Friday July 4, 2025. Among other changes to existing federal tax laws (many of which are discussed by other alerts from this firm), the OBBB Act...more

Morgan Lewis

New Section 174A Restores Domestic R&E Deductibility, but Other Changes Bring Mixed Results

Morgan Lewis on

President Donald Trump signed into law the One Big Beautiful Bill Act on July 4, 2025. Among many other provisions, this bill permits taxpayers to deduct domestic research and experimentation (R&E) expenditures under new...more

Cooley LLP

Senate Changes to Proposed Legislation Would Permit Immediate Deduction of Domestic R&E Expenditures Permanently, in Some Cases...

Cooley LLP on

On June 16, the Senate Finance Committee (SFC) released revisions to the “One Big Beautiful Bill Act” (OBBBA) passed by the US House of Representatives on May 22. As described in this June 4 Cooley client alert, the OBBBA...more

Cooley LLP

Proposed Tax Legislation Would Permit Immediate Deduction of Domestic R&E Expenditures for Limited Period

Cooley LLP on

On May 22, 2025, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA), which includes a temporary suspension of the amortization requirement for domestic research and experimentation (R&E)...more

Eversheds Sutherland (US) LLP

House confirms favorable modifications to three key business tax provisions

On May 12, 2025, the Republicans on the House Committee on Ways and Means released a draft bill showing their tax plan for the budget reconciliation legislation. The legislation will likely undergo significant changes as it...more

Miller Canfield

Are Wages for Research Credit Purposes Limited to “Reasonableness?”

Miller Canfield on

Smith v. Commissioner, a pending research credit case in the United States Tax Court, presents an issue of first impression: Is a partner’s self-employment income in a partnership allowable as a qualified research expense...more

Gray Reed

Federal Income Taxation of Intellectual Property Development and Cost Recovery

Gray Reed on

Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

Holland & Knight LLP

R&D Considerations in the Time of Non-Deductibility

Holland & Knight LLP on

The close of 2022 means family gatherings, holiday fun and one step closer to the end of research and development (R&D) expense current deductibility. Prior to the Tax Cuts and Jobs Act (TCJA), Internal Revenue Code Section...more

Miller Canfield

The Government's Use of Procedural Hurdles to Disallow Research Credit Refund Claims

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In two recent cases, the IRS has tried to defeat research credit refund claims on procedural grounds, rather than simply litigating whether the substantive nature of the asserted research meets the requirements of section 41...more

Mintz

Overview of Recent U.S. Tax Reform Part I – Certain Significant Changes Impacting C-Corporations

Mintz on

On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax...more

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