The supposed Treasury guidance would reopen access to major R&D tax breaks for large companies by easing limits imposed under the 15% minimum corporate tax.
- Treasury is drafting guidance to let companies fully claim retroactive R&D deductions restricted by the 15% minimum tax.
- The shift could free up tens of billions in benefits for research-intensive firms.
- It marks another step in softening the 2022 minimum corporate tax through exemptions and looser rules.
The U.S. Treasury Department is reportedly preparing guidance that would allow companies including Salesforce Inc. (CRM) and Qualcomm Inc. (QCOM) to fully use lucrative research and development deductions that have been restricted under Biden’s 15% minimum corporate tax.
R&D Deductions Blocked By Minimum Tax
The forthcoming proposal, which could be released as early as next week but remains under final review, is expected to resolve a conflict created when the Biden-era minimum tax on companies earning at least $1 billion prevented them from using retroactive R&D deductions in U.S. President Donald Trump’s “One Big Beautiful” tax bill, according to a report by Bloomberg.
Those deductions, reportedly worth an estimated $67 billion, are especially valuable to research-heavy sectors such as tech, pharmaceuticals and manufacturing.
Companies including Airbnb, Broadcom and Applied Materials have warned that the supersized deductions could trigger the minimum tax or limit hundreds of millions of dollars in credits related to earlier alternative minimum tax payments. Trump’s bill, passed in July, also restored full upfront research and development (R&D) spending, made loan-interest breaks permanent, expanded equipment write-offs and increased the state and local, or SALT deduction.
Treasury’s Broader Rollback Of Minimum Tax
If finalized, the guidance would mark the latest step in weakening the 2022 minimum tax. The Treasury has already issued more flexible rules, granted exemptions for insurance, shipping and utilities companies and allowed unrealized cryptocurrency gains to be excluded from the levy.
Tax analysts say Congress granted Treasury uncommon authority when drafting the law, giving the department room to reinterpret its scope. However, it is unclear whether the new guidance will also address corporate concerns about how R&D deductions interact with Trump-era international tax rules aimed at discouraging profit shifting overseas, the report said.
Trump Signals Broader Tax Ambitions
The report comes against a backdrop of expanding tax promises from Trump. Earlier this month, he said 2026 would be the “largest tax refund season ever,” citing tariff revenue collected over the past year that he said would be returned directly to households as a “dividend.”
Last month, he told U.S. service members his administration may “substantially” reduce and potentially eliminate income tax over the next two years, again pointing to rising tariff revenue, Reuters reported.
Separately, Trump said this week he is considering eliminating federal taxes on gambling winnings, expanding his push to reduce taxes on everyday income such as tips, Social Security and overtime pay. He said he would “think about” the proposal, which would affect millions of Americans who gamble each year and are currently subject to withholding rates of up to 28% on winnings above $5,000, according to IRS rules, according to a report by Fox Business.
How Did Stocktwits Users React?
On Stocktwits, retail sentiment for both Salesforce and Qualcomm was ‘neutral’ amid ‘normal’ message volume.
While Salesforce’s stock has declined 21% so far in 2025, Qualcomm’s stock has risen 20% over the same period.
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