Remaining unamortized amounts may be deducted at once or over two years
What the document says“to deduct such remaining unamortized amount with respect to such expenditures ratably over the 2-taxable year period beginning with the first taxable year beginning after December 31, 2024.”
The section lets a taxpayer with domestic research or experimental expenditures paid in taxable years beginning after December 31, 2021 and before January 1, 2025 that were charged to capital account elect to deduct the remaining unamortized amount either in the first taxable year beginning after December 31, 2024 or evenly over the two taxable years beginning with that year. Such a taxpayer is treated as initiating a change in method of accounting made with the Secretary's consent, applied only on a cut-off basis with no section 481(a) adjustments, and the Secretary must publish guidance including for taxpayers whose year began after December 31, 2024 and ended before enactment.
What the document actually says“to deduct such remaining unamortized amount with respect to such expenditures ratably over the 2-taxable year period beginning with the first taxable year beginning after December 31, 2024.”
The leftover amount may be spread over two tax years. The first is the year that begins after December 31, 2024.
The other choice is to deduct it all at once. That covers costs from 2022 through 2024 held on the books. The firm picks one.
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