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3. Navigating recent IRS guidance on R&E expenses

Planning Basis research deskSection 07 · Page 4 of 13Last updated 3 November 2026

Format/date: Tax Section Odyssey podcast, 10 September 2025. Who: April Walker with Mark Gallegos, as identified in AICPA’s episode listing. Link: Tax Section Odyssey — Navigating recent IRS guidance on R&E expenses, 10 September 2025

The publisher frames the episode around Revenue Procedure 2025-28 and choices for research/experimental expenditures. It is particularly relevant when an agency has actual software or development activity and needs to understand what questions a specialist will ask.

Take to your adviser: assemble activity descriptions, where the work happened and the historical accounting treatment. Ask separately about current expense treatment, historical elections and credit eligibility.

Best fit: businesses with a real R&E fact pattern; not every creative agency. Limit: the general 6 July 2026 retroactive-election deadline discussed in official guidance is now past. Use this episode as background and ask for a current procedural assessment. IRS — Internal Revenue Bulletin 2025-38: Revenue Procedure 2025-28

Sources cited on this page

  1. Tax Section Odyssey — Navigating recent IRS guidance on R&E expenses, 10 September 2025taxodyssey.libsyn.com
  2. IRS — Internal Revenue Bulletin 2025-38: Revenue Procedure 2025-28www.irs.gov