As a result of the Tax Cuts and Jobs Act (TCJA), beginning with tax years after December 31, 2021, Section 174 requires taxpayers to capitalize and amortize research and experimental expenditures. The TCJA also expanded the scope of research expenditures subject to section 174 to include software development costs, which means businesses no longer have the option to immediately expense those costs or use alternative amortization rules.
Reach out to our A&M Taxand Section 174 experts today to schedule an initial assessment where we discuss how this will impact your business.
IRS Creates Limited Opportunity to Revisit “Irrevocable” §163(j) Elections
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Revenue Procedure 2026-17 creates a limited window to revoke certain “irrevocable” §163(j) elections, including the RPTOB and CFC group elections, in light of OBBBA-driven changes.
India Tax Alert | The Corporate Laws (Amendment) Bill, 2026
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The Bill represents a significant shift toward streamlining corporate restructuring and reducing the regulatory friction for M&A transactions. Here is a summary of the key provisions from an M&A and restructuring perspective.
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On March 10, 2026, the Spanish Council of Ministers approved the signing of a new double tax treaty between Spain and the Netherlands, formally replacing the current agreement signed in 1971, one of the oldest treaties in Spain’s tax treaty network.
Key Transitional Issues for FY2025 CIT Finalization Under New Decree No. 320/2025/ND-CP & Circular 20/2026/TT-BTC
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Explore key transitional issues for FY2025 CIT finalization in Vietnam under Decree 320/2025/ND‑CP and Circular 20/2026/TT‑BTC.
