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KPMG article: OBBBA restores R&E expensing, alters multinational tax strategy

OBBBA restores immediate domestic R&E expensing while reshaping CAMT, BEAT, FDDEI, and R&D credit planning.

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June 9, 2026

The “One Big Beautiful Bill Act” (OBBBA) delivers the long-anticipated return of immediate deductibility of domestic research and experimental (R&E) expenditures. While the baseline cash flow benefits are clear—including options to accelerate deductions for costs capitalized between 2022 and 2024—the restoration of R&E expensing triggers significant ripple effects across a company’s broader tax profile.

Altering how and when R&E costs are deducted creates a chain reaction across other complex tax frameworks. The immediate cash tax savings can simultaneously shift a company’s exposure and strategic approach regarding the corporate alternative minimum tax (CAMT), the base erosion and anti-abuse tax (BEAT), foreign-derived deduction eligible income (FDDEI), and overall research and development (R&D) credit optimization.

Read a June 2026 article* prepared by KPMG LLP tax professionals that discusses these interconnected impacts and outlines practical considerations for leadership. Ultimately, maximizing the value of the OBBBA requires comprehensive financial modeling to navigate these overlapping regimes, manage risk, and ensure that tax strategies align with broader business objectives.

*Reproduced with permission from Tax Management International Journal, 6/9/2026. © 2026 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com

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