The change counts as a change in accounting method on a cut-off basis
What the document says“The amendments made by subsection (a) shall be treated as a change in method of accounting for purposes of section 481 of the Internal Revenue Code of 1986 and--”
The section treats the new deduction as a change in method of accounting under section 481 of the Internal Revenue Code of 1986, initiated by the taxpayer, made with the Secretary's consent, and applied only on a cut-off basis for domestic research or experimental expenditures paid or incurred in taxable years beginning after December 31, 2024, with no section 481(a) adjustments. For a taxable year beginning after that date and ending before enactment, the cut-off rule does not apply and the change is made on a modified cut-off basis counting only such costs paid in that year and not deducted in it.
What the document actually says“The amendments made by subsection (a) shall be treated as a change in method of accounting for purposes of section 481 of the Internal Revenue Code of 1986 and--”
The change counts as a change in how the books are kept. The rules that follow set how it works.
The firm counts as having started the change. The Secretary counts as having agreed. Older years are not reopened.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.