ABSTRACT This paper analyzes the revisions to Internal Revenue Code (I.R.C.) § 174 under the 2017 Tax Cuts and Jobs Act (TCJA) and the 2025 One Big Beautiful Bill Act (OBBBA). To better understand these revisions, we analyze the historical tax treatment of research and experimentation (R H20; H25.
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The ATA Journal of Legal Tax Research
Missouri State University
University of North Georgia
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