SECTION 1. PURPOSE

This revenue procedure modifies section 7 of Rev. Proc. 2025-23, 2025-24 I.R.B. 1476, as modified by Rev. Proc. 2025-28, 2025-38 I.R.B. 393, with respect to the procedures under § 446 of the Internal Revenue Code (Code) ¹ and § 1.4461(e) for obtaining automatic consent of the Commissioner of Internal Revenue (Commissioner) 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 115-97, 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 11921, 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.

This revenue procedure also modifies section 19 of Rev. Proc. 2025-23 with respect to the 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.