One Big Beautiful Bill Act of 2025 (“OBBBA”) is the most sweeping change to the federal R&D tax landscape since §174 capitalization was enacted under the TCJA. The new law restores full and immediate deductibility of U.S.-based R&D expenditures and makes that change retroactively available for 2022, 2023, and 2024 for eligible small businesses.
For taxpayers—including pass-throughs, C-corps, and multi-state technology companies—the next 12–18 months involve critical compli