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OBBBA Retroactive Election
Amending 2022–2024 returns for immediate R&D expensing
Guide
Eligibility: The $31M Gross Receipts Test
The §448(c) test with §52 controlled group aggregation. Average annual gross receipts ≤$31M (inflation-adjusted 2025). Controlled group trap explained.
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Guide
Two Filing Paths: Amended Returns vs. Method Change
Path 1: Amended returns per Section 3.03 of Rev. Proc. 2025-28. Path 2: Automatic method change with §481(a) adjustment on 2024 return.
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Checklist
The July 6, 2026 Deadline — and Why It May Be Earlier
Final deadline for retroactive elections. The §6511 statute may close earlier: 2022 returns filed April 15, 2023 close April 15, 2026.
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Guide
Partnership AARs Under the BBA Audit Regime
BBA partnerships make the retroactive election via AAR, not amended returns. Push-out mechanics and partner-level tax impact timing.
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