Identify how the One Big Beautiful Bill Act (OBBBA) modifies the treatment of domestic and foreign research and experimental (R&E) expenses under IRC Section 174.

Recall the interaction between Section 174 deductions and the Section 41 R&D credit, including implications of the Section 280C adjustment.

Recognize the documentation, filing requirements, and IRS guidance under Rev. Proc. 2025-28 for making method changes and claiming deductions.

Distinguish between expensing and amortization strategies and their effects on pass-throughs, state taxes, and financial reporting.