Rev. Proc. 2025-28 provides a practical framework for large taxpayers and taxpayers treated as tax shelters to implement the new §174A rules beginning in 2025 and to accelerate recovery of domestic §174 costs that were capitalized during 2022–2024. For most large taxpayers, the starting point is simple: the taxpayer’s accounting method choice is reflected by … Read more
What CPAs Need to Know About Timing, Method Changes, and Missed Opportunities Introduction Recent legislative changes have reshaped how several long-standing tax incentives operate in practice. For CPAs, the result has been a mix of opportunity and confusion—particularly at the intersection of the Research & Development (R&D) tax credit, mandatory capitalization under Section 174, and … Read more
For years, taxpayers have been stuck with one of the least popular provisions of the 2017 tax reform: the mandatory capitalization of research and experimental (R&E) costs. Instead of writing off innovation expenses immediately, businesses were forced to spread deductions over five years for domestic research and fifteen years for foreign research. This created cash … Read more
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