R&D Tax Credit Insights & Analysis

Landmark Tax Court Ruling Puts R&D Credits at Risk

The U.S. Tax Court’s December 2024 decision in Phoenix Design Group, Inc. v. Commissioner (T.C. Memo 2024-113) is a landmark case for engineering and professional services firms. The court denied R&D tax credit claims and upheld a 20% accuracy-related penalty under IRC §6662, citing insufficient contemporaneous documentation, lack of objective technical uncertainty, and no systematic process of experimentation required under §41(d). This ruling highlights the critical need for audit-ready documentation, activity-level time tracking, and applying the shrinking-back rule to protect R&D credit eligibility.

GENIUS Act and Its Role in Blockchain R&D Tax Credits

The GENIUS Act, signed into law in July 2025, establishes the first federal framework for stablecoins, requiring 1:1 dollar or Treasury backing, transparency, and regulated issuers. For blockchain and Web3 companies, this reduces uncertainty and aligns with the repeal of Section 174 amortization, which restores immediate expensing of U.S.-based R&D costs. Together, these changes create powerful opportunities to claim R&D tax credits. Startups may offset up to $500,000 in payroll taxes annually, while larger firms can recover a portion of development spend. Eligible activities include smart contract development, scalability experiments, custody integrations, DeFi protocols, and enterprise pilots. With regulatory clarity and financial incentives combined, the U.S. is now one of the most favorable jurisdictions globally for blockchain R&D.

Maximize R&D Tax Savings with IRS Rev. Proc. 2025-28 and OBBBA

IRS Rev. Proc. 2025-28 implements the One Big Beautiful Bill Act (OBBBA), restoring immediate §174A R&D expensing, simplifying §280C elections, and opening a refund window for 2022–2024 tax years. Small businesses can file amended or superseding returns to recover cash, while larger companies gain streamlined compliance with automatic accounting method changes. This guidance marks a turning point after TCJA’s capitalization rules, offering clarity, cash flow relief, and planning opportunities for innovative taxpayers.

Impact of IRC §280C Elections for R&D Tax Credit Claimants After OBBBA

The single guide to the Section 280C election after OBBBA: what the statute requires, Form 6765 filing mechanics, Schedule M-1 and M-3 treatment, the TCJA years, and when the election is worth making.

Debunking Section 174 Amortization Myths: Avoid R&D Tax Pitfalls

The One Big Beautiful Bill Act (OBBBA), signed into U.S. law on July 4, 2025, repeals Section 174 amortization for domestic R&D expenses, restoring immediate expensing starting in 2025. This change boosts cash flow, strengthens the value of Section 41 R&D tax credits, and supports U.S. businesses investing in innovation. But myths are spreading—about retroactive refunds, foreign R&D, software development, audits, and double-dipping under Section 280C. In this blog, Strike Tax Advisory debunks the top misconceptions, explains who qualifies for retroactive expensing (including the $31M small business threshold), and shows how startups and established companies can maximize credits, deductions, and hiring potential under OBBBA. If you’re searching for clear answers on “OBBBA Section 174 repeal,” “R&D tax credit myths 2025,” or “how to claim retroactive R&D deductions,” this guide breaks it down step by step.

The One Big Beautiful Bill Act (OBBBA) and the R&D Tax Credit

The U.S. House has passed the One Big Beautiful Bill Act (OBBBA), officially repealing Section 174 amortization and restoring immediate expensing for domestic R&D costs. This landmark change means small businesses (with under $31 million in annual gross receipts) could retroactively amend 2022-2024 tax returns to claim full deductions and receive refunds for previously amortized R&D expenses. Larger businesses can accelerate remaining deductions in 2025 and 2026. Foreign R&D costs must still be amortized over 15 years. With immediate expensing back, the Section 41 R&D Tax Credit becomes more valuable, unlocking significant cash flow and refund opportunities for innovative companies. The retroactive election window closed on July 6, 2026; open year credit claims and the catch-up deduction remain available.

Senate Approves OBBBA with Section 174 R&E Relief

The U.S. Senate has passed the One Big Beautiful Bill Act (OBBBA), delivering retroactive Section 174 R&E tax relief for small and medium-sized enterprises (SMEs). This landmark legislation allows qualifying businesses to immediately expense domestic research and experimental costs back to 2022, potentially unlocking millions in tax savings and boosting innovation. The bill now moves to the House of Representatives, where its retroactive relief provisions will be debated. SMEs are encouraged to consult tax experts, monitor legislative updates, and use StrikeTax’s R&D Tax Credit Calculator to maximize benefits. For ongoing updates and expert guidance, visit StrikeTax.com.

Section 174 Repeal: Big Win for SMEs in Senate Tax Reform

The Senate’s latest tax reform proposal includes a potential repeal of Section 174 amortization, offering SMEs the opportunity for immediate expensing of domestic R&D costs and retroactive tax benefits if enacted. This blog explains what will change, how SMEs can prepare, and what to watch for as the bill moves through Congress. Stay informed and ready to maximize your R&D tax savings if the new law is passed.

Pending 2025 Tax Bill Promises Section 174 Repeal

2025 tax bill draft document with Section 174 repeal highlighted for R&D tax relief.

2025 IRS Form 6765 Updates: Maximize R&D Tax Credits

The 2025 IRS Form 6765, used to claim R&D tax credits, introduces stricter reporting requirements.

Section 174 Relief: Estes’ R&D Bill Boosts Innovation in 2025

The Estes American Innovation and R&D Competitiveness Act offers a clear fix for Section 174’s innovation drag—immediate expensing, retroactive relief, likely resulting in major economic lift.

Section 174 Repeal Update: How OBBBA Section 174A Restored Immediate R&D Expensing

Section 174 amortization was repealed by OBBBA in July 2025. New Section 174A restores immediate domestic R&D expensing for tax years beginning after December 31, 2024. Eligible small businesses can amend 2022, 2023, and 2024 returns retroactively under Rev. Proc. 2025-28, with a deadline of July 6, 2026 or the Section 6511 statute of limitations, whichever is earlier. Here is what to do next.