The "American Innovation and R&D Competitiveness Act of 2025" aims to restore the immediate deductibility of research and experimental (R&E) expenditures for businesses. This legislation amends Section 174 of the Internal Revenue Code of 1986, reversing a prior change that required these expenses to be amortized over a period of years. The bill allows taxpayers to treat R&E costs as current expenses in the taxable year they are paid or incurred, without requiring consent from the Secretary for their first year. Alternatively, taxpayers may elect to amortize certain R&E expenditures over a period of not less than 60 months, beginning when benefits are first realized. This option applies to expenses not treated as immediate deductions and not subject to depreciation or depletion allowances. The bill explicitly excludes expenditures for land acquisition, property subject to depreciation, or mineral exploration from these provisions, and only reasonable expenditures are eligible. The Act also includes conforming amendments to other sections of the Internal Revenue Code, such as Section 41, which deals with the credit for increasing research activities, and Section 280C, regarding the disallowance of deductions for certain credits. These amendments clarify how the research credit interacts with the restored deduction, including an option for taxpayers to elect a reduced credit to avoid a deduction disallowance. Critically, these changes are made retroactive , applying to taxable years beginning after December 31, 2021.
American Innovation and R&D Competitiveness Act of 2025
USA119th CongressHR-1990| House
| Updated: 3/10/2025
The "American Innovation and R&D Competitiveness Act of 2025" aims to restore the immediate deductibility of research and experimental (R&E) expenditures for businesses. This legislation amends Section 174 of the Internal Revenue Code of 1986, reversing a prior change that required these expenses to be amortized over a period of years. The bill allows taxpayers to treat R&E costs as current expenses in the taxable year they are paid or incurred, without requiring consent from the Secretary for their first year. Alternatively, taxpayers may elect to amortize certain R&E expenditures over a period of not less than 60 months, beginning when benefits are first realized. This option applies to expenses not treated as immediate deductions and not subject to depreciation or depletion allowances. The bill explicitly excludes expenditures for land acquisition, property subject to depreciation, or mineral exploration from these provisions, and only reasonable expenditures are eligible. The Act also includes conforming amendments to other sections of the Internal Revenue Code, such as Section 41, which deals with the credit for increasing research activities, and Section 280C, regarding the disallowance of deductions for certain credits. These amendments clarify how the research credit interacts with the restored deduction, including an option for taxpayers to elect a reduced credit to avoid a deduction disallowance. Critically, these changes are made retroactive , applying to taxable years beginning after December 31, 2021.