The guidance covers procedures for amortising domestic R&E costs, obtaining automatic consent for accounting changes, and extended deadlines for certain 2024 returns.
The IRS released Revenue Procedure 2025-28, outlining rules for elections, amended returns, and accounting method changes related to research and experimental expenses under the One, Big, Beautiful Bill Act (OBBBA).
It provides procedures for making certain elections under § 70302(f) of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the OBBBA, for domestic research or experimental expenditures. This revenue procedure modifies procedures under § 446 of the Internal Revenue Code (Code)1 and § 1.446-1(e) for obtaining automatic consent of the Commissioner of Internal Revenue (Commissioner) to (i) change methods of accounting for research or experimental expenditures under § 174, as in effect after amendment by § 13206(a) of Public Law 115-97, 131 Stat. 2054 (Dec. 22, 2017), commonly known as the Tax Cuts and Jobs Act (TCJA), and prior to amendment by § 70302(b)(1) of the OBBBA, and (ii) change methods of accounting to comply with §§ 174 and 174A (as amended and enacted by the OBBBA, respectively).
This revenue procedure also provides procedures for making elections under § 174A(c) to amortise domestic research or experimental expenditures paid or incurred in taxable years beginning after 31 December 2024.
Finally, for a taxable year beginning during 2024 and ending prior to 15 September 2025, for which the due date (excluding any extension) for the return of tax for such taxable year was before 15 September 2025 (2024 taxable year), section 8 of this revenue procedure grants an automatic extension of time to file superseding tax and information returns applying the provisions of this revenue procedure.
US President Donald Trump signed the “One Big Beautiful Bill” into law on 4 July 2025.
