Rev. Proc. 2026-32, page 406.

Revenue Procedure 2026-32 provides procedures under § 446 of the Internal Revenue Code and § 1.446-1(e) for obtaining automatic consent of the Commissioner of Internal Revenue to change methods of accounting for research or experimental expenditures (i) to comply with § 174, as in effect after amendment by § 13206(a) of Public Law 11597, 131 Stat 2054 (Dec. 22, 2017), commonly known as the Tax Cuts and Jobs Act (TCJA), and prior to amendment by § 70302(b)(1) of Public Law 119-21, 139 Stat. 189, 239 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), and (ii) to comply with §§ 174 and 174A, as amended and enacted by the OBBBA, respectively.

Revenue Procedure 2026-32 also provides procedures under § 446 and § 1.446-1(e) for obtaining automatic consent of the Commissioner to change methods of accounting for contracts entered into in taxable years beginning after July 4, 2025, to comply with § 460(e), as amended by the OBBBA.