The IRS released guidance Thursday, Aug. 28, in Rev. Proc. 2025-28 advising taxpayers how to handle making various elections, filing amended returns, and changing accounting methods for research or experimental expenditures, as provided under Section 70302 of H.R. 1, commonly known as the One Big Beautiful Bill Act.
The revenue procedure also modifies Rev. Proc. 2025-23, List of Automatic Changes, and allows more time for partnerships, S corporations, C corporations, individuals, estates and trusts, and exempt organizations to file superseding 2024 federal income tax returns.
In addition, for domestic research or experimental expenditures paid or incurred in a tax year beginning after Dec. 31, 2024, a trade or business of a taxpayer (applicant) may elect to capitalize and amortize all such expenditures paid or incurred in the tax year under Sec. 174A(c) with one exception.
The applicant cannot have changed its method of accounting with respect to domestic research or experimental expenditures under Section 7.02(3) of Rev. Proc. 2025-23, as modified by this revenue procedure, for such tax year. Read more.