Practical Section 174A Tax Planning in the Post-OBBBA Landscape

This article was originally published for The Tax Adviser.

In enacting new Section 174A, the One Big Beautiful Bill Act (OBBBA) brought the highly anticipated return of immediate expensing for domestic research and experimental (R&E) expenditures. In returning flexibility to the treatment of domestic R&E, Section 174A also brings new, multivariable planning challenges for taxpayers and interpretive challenges for practitioners. 

This article explores the implications taxpayers’ domestic R&E choices can have on the broader tax landscape, highlights some ambiguity in new Section 174A, and offers practical suggestions for tackling related planning challenges. 

BDO’s Nicole Allen Yee and Lori Anne Johnston provide full details for this article in The Tax Adviser.