News & Analysis as of

Research and Development Tax Cuts and Jobs Act

Latham & Watkins LLP

One Big Beautiful Bill Introduces Major Changes to Federal Tax Law

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the OBBB) into law, making permanent the reduced individual tax rates and brackets established by the Tax Cuts and Jobs Act of 2017 and modifying a...more

King & Spalding

Sweeping Tax Legislation Signed into Law

King & Spalding on

On July 4, President Trump signed into law H.R. 1, (the “One Big Beautiful Bill Act” (“OBBBA”)), a sweeping legislation package featuring significant changes to U.S. tax law. The OBBBA was passed via a budget reconciliation...more

Ballard Spahr LLP

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

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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

Goodwin

One Big Beautiful Bill Act - Tax Highlights related to Research and Experimental Expenditures, Qualified Small Business Stock and...

Goodwin on

On July 4, 2025, the One Big Beautiful Bill Act (OBBB) was signed into law. The OBBB extends various expiring tax provisions from the Tax Cuts and Jobs Act (TCJA) and introduces a variety of other substantial tax law changes....more

BakerHostetler

Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more

Goodwin

One Big Beautiful Bill Act - Tax Implications for Life Sciences Industry

Goodwin on

On July 3, 2025 Congress passed, and on July 4, 2025 President Trump signed into law, the One Big Beautiful Bill Act (OBBB), which extends various expiring tax provisions from the Tax Cuts and Jobs Act and introduces a...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

Wilson Sonsini Goodrich & Rosati

Senate Finance Committee Proposes Permanently Restoring Expensing for Domestic R&D Expenditures

On June 16, 2025, the Senate Finance Committee released its draft of the tax provisions in H.R. 1 (commonly referred to as the “One Big Beautiful Bill” (the SFC Bill)). We previously covered the original legislation passed by...more

Eversheds Sutherland (US) LLP

Senate’s version would permanently extend TCJA provisions and close interest loopholes

On June 16, 2025, the Senate Finance Committee released proposed text for tax provisions to be included in the Senate’s version of the One Big Beautiful Bill Act (OBBB). Our prior Alert addresses the House version of the...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

Eversheds Sutherland (US) LLP

Proposed bill aims to postpone TCJA limits on business incentives

Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more

Eversheds Sutherland (US) LLP

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...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

Cooley LLP

IRS Publishes Guidance on Tax Rules for Software Development, Research Expenses

Cooley LLP on

The Tax Cuts and Jobs Act of 2017 (TCJA) introduced significant changes to the tax treatment of specified research and experimentation (SRE) expenditures. Historically, companies were able to immediately deduct all costs...more

Eversheds Sutherland (US) LLP

An olive branch or shot across the bow? IRS issues Notice 2023-63 providing welcome substantive Section 174 guidance

The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more

Holland & Knight LLP

R&D Considerations in the Time of Non-Deductibility

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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

Harris Beach Murtha PLLC

Key Tax Provisions of the Inflation Reduction Act of 2022

On August 16, 2022, President Joe Biden signed the Inflation Reduction Act of 2022 (the “Act”) into law. Among its provisions, the Act provides the biggest investment ever in the US to fight climate change, places a cap on...more

Polsinelli

Capitol Hill Watch: R&D Tax Fix On the Table But Fate Uncertain

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As Congress faces a March 11 deadline to enact a Fiscal Year 2022 omnibus spending bill, advocates are making their case to federal legislators this week to include a tax title that delays or repeals the five-year...more

Eversheds Sutherland (US) LLP

The devil is in the details: Final infrastructure framework announced, fingers crossed for continued R&E deductibility

Democratic leadership announced today that an agreement has been reached to fund the pending infrastructure and budget reconciliation measures. There does not appear to be any agreement regarding which specific tax measures...more

McDermott Will & Emery

Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

McDermott Will & Emery on

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more

Mintz

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

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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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