[taxopinion]

> As the article suggests some are just filing incorrectly, what are the real risks and consequences of this?

Provided you never used an R&D tax credit, none.

But if you did, with a huge templated report report about software R&D, you have a verbatim provable record of doing R&D expenses. And those reports, they come from 10 different vendors who all use the same words and formatting. The IRS could easily solve one case and get everyone.

[ilandsman]

Just to clear this up, this change is unrelated to if you've taken the R&D credit. You should take it as it slightly helps offset this change, but regardless the calculation applies to dev salaries and costs without regard to if you've actually taken the R&D credit.