Update: What the One Big Beautiful Bill Means for R&D Strategy Today

With the One Big Beautiful Bill (H.R. 1) now signed into law, immediate R&D expensing has been permanently restored, and new tax-saving opportunities are in motion for businesses of ALL sizes. 

Section 174A allows immediate expensing of domestic R&D starting in 2025 and provides retroactive relief for small businesses that meet specific criteria. The runway has also been cleared for businesses of all sizes to be made whole on amortized R&D expenses.  The law is clear—and the time to act is now. 

What Businesses Should Be Doing

With implementation procedures in motion, the law already opens strategic doors for proactive businesses. Whether you’re preparing for a timely filing or considering amended returns, key actions today will set the stage for stronger outcomes tomorrow. 

What Happens Next Before It Becomes Law 

• Immediate expensing or amortization options under Section 174A begin with tax year 2025 

• Small businesses (under $31M average gross receipts) may amend 2022 and 2023 returns to: 
  • Reflect full expensing
  • Make or update prior §280C elections 

• The statutory window for amended returns tied to the law’s enactment runs through July 4, 2026, though certain late-election scenarios may have earlier cutoffs 

• Businesses over $31M in gross receipts that previously amortized R&D expenses will have the opportunity to “turbo depreciate” 174 expenses in 2025—leveraging the new expensing rules to effectively catch up and align with the immediate expensing treatment moving forward
  
  
• Businesses over $31MM have avenues to amend for the credit and be made whole on any amortized expenses from that as well 

Why Early Preparation Matters

Whether you’ve already filed or are planning ahead, early strategy work improves flexibility and control. With new rules in place, filing positions, timing, and documentation choices will directly impact compliance and benefits. 

2024 is also a key bridge year. Filing under current rules may help avoid complications as new IRS forms and requirements phase in for 2025.  In addition, timely filing 2024 extended returns with R&D tax credits allows the taxpayer to take control of the timing of tax savings while avoiding additional amendment requirements. 

What Businesses Should Be Doing Now

To prepare for evolving requirements and optimize tax outcomes: 

• Review 2022 through 2024 R&D activity to identify eligible expenses 

• Model tax scenarios under both amended return and 2025 forward-looking strategies 

• Gather and prepare documentation, including R&D studies, §280C analysis, and financial modeling 

• Engage in strategy sessions with your CPA and ABGi to align on the best path based on your filing position, eligibility, and risk profile 
  
  
• Develop a filing plan to ensure readiness—whether you plan to file now, amend later, or supersede with updated elections 
  

ABGi's Role: Strategic Guidance Without the Guesswork

ABGi is actively supporting clients in two core tracks: 

• Small businesses preparing retroactive filings under the law 

• Larger businesses planning for 2025 elections, cash flow modeling, and compliance alignment- including how to turbo depreciate prior R&D expenses and be made whole through 2025 filings 

Our role is to provide fact-based insights, technical modeling, and CPA-aligned support—not speculation. Whether you’re filing next month or strategizing for next year, we’ll help you build a plan rooted in clarity, compliance and opportunity. 

The Cost of Delay

With filing queues, election windows, and refund opportunities all in play, the opportunity is real—but not indefinite. Missing key steps now could lead to missed refunds, compliance risk, or forced amortization treatment when better options were available. 

The message is clear: “wait and see” is not a strategy. The smartest move is to prepare today so you're ready—no matter what process the IRS sets tomorrow. 

ABGi is ready to support your team, your CPA, and your goals. Let’s get to work. 

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