ARTICLE
31 July 2025

R&D, ERC, And Energy Credits: What 2025 Tax Reform Means For You

MG
MGO CPA LLP

Contributor

As a global team of more than 500 financial service professionals, we stand ready to serve you through assurance, tax, consulting, outsourcing, and private client services where and when you need us.
The 2025 tax landscape is shifting dramatically — and mid-market CFOs and tax leaders are being forced to rethink their planning in real time. In a recent webinar hosted by MGO...
United States Tax

Key Takeaways:

  • Immediate R&D expensing may return in 2025, but many companies haven't modeled the impact or updated their budgets to reflect the change.
  • Heightened IRS scrutiny of the Employee Retention Credit is prompting CFOs to audit past claims and tighten documentation to avoid penalties.
  • Accelerated clean energy credit deadlines are forcing businesses to fast-track investments and project timelines to maximize available incentives.

The 2025 tax landscape is shifting dramatically — and mid-market CFOs and tax leaders are being forced to rethink their planning in real time. In a recent webinar hosted by MGO, hundreds of finance professionals weighed in on how three major areas are impacting their strategy: Section 174 research and development (R&D) treatment, IRS enforcement around the Employee Retention Credit (ERC), and the accelerated rollback of clean energy tax credits.

Here's what your peers are saying — and what you should be doing now to stay ahead:

Key Insight #1: Section 174 Relief Is Coming — But Not Everyone Is Ready

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Takeaway:

The upcoming allowance for immediate expensing of domestic R&D starting in 2025 offers cash flow relief. Yet many companies still haven't modeled the impact — or taken advantage of transition-year elections.

Action items:

  • Model multi-year R&D tax savings now
  • Explore amending 2022–2024 returns under new rules
  • Build R&D forecasting into 2025–2026 budgeting

Key Insight #2: ERC Enforcement Concerns Are Rising

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Takeaway:

With expanded penalties, longer statutes of limitation, and uncapped promoter fines, the IRS is sending a clear message: ERC compliance is a top audit priority.

Action items:

  • Conduct an internal audit of any ERC claims
  • Review Q3 2021 filings for risk exposure
  • Tighten documentation — especially for eligibility support
  • Monitor communications from IRS for pre-audit activity

Key Insight #3: Clean Energy Credit Deadlines Require Immediate Action

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Takeaway:

New end dates for §45W and §30C credits create urgency around construction, delivery, and placed-in-service deadlines. Many companies still haven't adjusted timelines to capture full benefits.

Action items:

  • Accelerate capital expenditure for EVs and charging infrastructure
  • Confirm placed-in-service dates for Q3 and Q4 2025
  • Consider design changes to meet prevailing wage rules
  • Review supply chain for prohibited foreign entity risks

Proactive Beats Reactive in a Shifting Tax Environment

The 2025 tax landscape is a moving target, but that doesn't mean you need to wait in limbo. CFOs and tax leaders who act early — by reassessing R&D strategies, auditing ERC positions, and accelerating energy investments — stand to gain the most. With cash flow, compliance, and credit all on the line, now is the moment to turn insights into action. Whether you're facing uncertainty or opportunity, a proactive approach will help you lead with confidence and clarity in the year ahead.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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