Tax strategies Key insights Revisit Section 174 treatment for 2022 – 2024 before claiming new credits; the same activities that create credit opportunity may also reveal prior-year capitalization risk. The July 6, 2026, deadline applies if you want retroactive Section 174 relief through amended returns, but it’s not the only path available. Model the tax, cash flow, and administrative impact before amending: a method change or prospective approach may be more practical based on your situation. Clarify R&D credit options before you amend your returns. Section 174 risk for 2022 – 2024 tax years The George v. Commissioner decision (February 2026) opened the door for businesses that have not previously claimed R&D tax credits or fully identified research and experimental costs to reevaluate their activities. Recent legislative changes have also introduced both opportunity and potential exposure. From 2022 – 2024, taxpayers were required under Section 174 to capitalize and amortize domestic R&E costs over a five-year period, regardless of whether a credit was claimed. Many businesses did not fully identify these costs for capitalization because they did not believe their activities met the definition of R&E. By looking at operations (particularly in agribusiness , manufacturing, and technology) in a new light as a result of George, credits certainly may be available, but it may also highlight a risk area: Undercapitalized R&E costs in prior years can lead to tax penalties Claiming an R&D credit without having 174A costs identified could cause risk both in the validity of the credit along with the proper treatment of these costs Revisiting prior-year filings to align can draw scrutiny July 6 deadline for amended returns For small taxpayers (under $31 million in gross receipts), OBBBA allows retroactive relief to fully expense Section 174 costs for 2022 – 2024 by moving the effective date of the provision back — but any amended returns using this option must be filed by July 6, 2026. The July 6 deadline creates urgency but not necessity. Taxpayers should fully model their options, understand the trade-offs, and prioritize accuracy over speed to support long-term results. For taxpayers that did not capitalize costs but may have needed to, moving the effective date of the provision, as if capitalizing domestic 174 costs was never a requirement, could provide protection via an election statement within the amended returns. This accelerated deadline is a significant departure from the typical three-year statute and requires careful analysis before acting. Amending, which is optional, may make sense if: You have significant deferred costs from 2022 – 2024 The expected benefit is immediate and material Prior-year filings are relatively straightforward Alternate approaches to amending tax returns While amending returns may seem attractive, it’s not always the best path. Changes to taxable income can trigger downstream impacts — AMT exposure, interest limitations, or shareholder-level consequences — and refunds may be delayed due to IRS backlog. In addition, administrative burdens of amending all applicable returns (including shareholders) may be unnecessary. An alternative is filing a method change (Form 3115) with the 2025 return, allowing taxpayers to correct Section 174 treatment while spreading income adjustments over time and potentially leveraging favorable timing benefits under OBBBA. Waiting or taking a prospective approach may make more sense if: The structure is complex (multiple entities or owners) The benefit changes after modeling credits and other impacts Administrative effort outweighs near-term gain How CLA can help with R&D credits R&D tax credits can still be claimed on amended returns under normal statutes, meaning the July 6 deadline may not apply in all cases. However, coordination with Section 280C elections — which affect how the credit and related deductions are balanced — is an important part of the overall tax strategy. CLA can help you evaluate how R&D credits and Section 174 interact across prior and current years so decisions made now don’t create issues later. We work with you to identify qualifying activities, assess capitalization exposure, and compare options like amending returns or filing a method change. We also help align documentation and filing positions to support timing decisions and stand up to IRS review. Contact us Clarify R&D credit options before you amend your tax returns. Complete the form below to connect with CLA. Connect © 2026 CliftonLarsonAllen. All rights reserved. "CliftonLarsonAllen" and "CLA" refer to CliftonLarsonAllen LLP. Securities and investment advisory services are offered through CliftonLarsonAllen Wealth Advisors, LLC, an SEC-registered investment advisor, member FINRA/SIPC. CliftonLarsonAllen is a Minnesota LLP, with more than 120 locations across the United States. The Minnesota certificate number is 00963. The California license number is 7083. The Maryland permit number is 39235. The New York permit number is 64508. The North Carolina certificate number is 26858. 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