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139 STAT. 194 PUBLIC LAW 119–21—JULY 4, 2025 (f) TRANSITION RULES.— (1) ELECTION FOR RETROACTIVE APPLICATION BY CERTAIN SMALL BUSINESSES.— (A) IN GENERAL.—At the election of an eligible tax- payer, paragraphs (1) and (3) of subsection (e) shall each be applied by substituting ‘‘December 31, 2021’’ for ‘‘December 31, 2024’’. An election made under this subpara- graph shall be made in such manner as the Secretary may provide and not later than the date that is 1 year after the date of the enactment of this Act. The taxpayer shall file an amended return for each taxable year affected by such election. (B) ELIGIBLE TAXPAYER.—For purposes of this para- graph, the term ‘‘eligible taxpayer’’ means any taxpayer (other than a tax shelter prohibited from using the cash receipts and disbursements method of accounting under section 448(a)(3)) which meets the gross receipts test of section 448(c) for the first taxable year beginning after December 31, 2024. (C) ELECTION TREATED AS CHANGE IN METHOD OF ACCOUNTING.—In the case of any taxpayer which elects the application of subparagraph (A)— (i) such election may be treated as a change in method of accounting for purposes of section 481 of such Code for the taxpayer’s first taxable year affected by such election, (ii) such change shall be treated as initiated by the taxpayer for such taxable year, (iii) such change shall be treated as made with the consent of the Secretary, and (iv) subsection (c) shall not apply to such taxpayer. (D) ELECTION REGARDING COORDINATION WITH RESEARCH CREDIT.—An election under section 280C(c)(2) of the Internal Revenue Code of 1986 (or revocation of such election) for any taxable year beginning after December 31, 2021, by an eligible taxpayer making an election under subparagraph (A) shall not fail to be treated as timely made (or as made on the return) if made during the 1-year period beginning on the date of the enactment of this Act on an amended return for such taxable year. (2) ELECTION TO DEDUCT CERTAIN UNAMORTIZED AMOUNTS PAID OR INCURRED IN TAXABLE YEARS BEGINNING BEFORE JANUARY 1, 2025.— (A) IN GENERAL.—In the case of any domestic research or experimental expenditures (as defined in section 174A, as added by subsection (a)) which are paid or incurred in taxable years beginning after December 31, 2021, and before January 1, 2025, and which was charged to capital account, a taxpayer may elect— (i) to deduct any remaining unamortized amount with respect to such expenditures in the first taxable year beginning after December 31, 2024, or (ii) to deduct such remaining unamortized amount with respect to such expenditures ratably over the 2-taxable year period beginning with the first taxable year beginning after December 31, 2024. Time periods. Effective date. Time period. Definition. Deadline.