OBBBA's new Section 174A restored immediate expensing for domestic research and experimental costs (foreign R&E still amortizes over 15 years), and Rev. Proc. 2025-28 supplied the transition mechanics—the catch-up of 2022–2024 capitalized amounts and the small-business retroactivity election, whose July 6, 2026, window has now closed. But some substantive questions remain unsettled—the scope of what counts as R&E, software-development costs, coordination with the Section 41 credit and Section 280C, and the Section 163(j) interaction—and Treasury is expected to issue guidance before year-end addressing these open issues. This panel takes stock of what OBBBA and Rev. Proc. 2025-28 have settled, what the forthcoming guidance is likely to resolve, and the questions on the margin that practitioners are navigating in the meantime.