Glossary/Tax and regulatory

Section 174 research expenditures

Section 174 covers research and experimental expenditures, and for tax years beginning after 2024 section 174A allows domestic costs to be deducted immediately while foreign research costs remain amortized over 15 years.

CORAA TeamUpdated November 5, 2026

Definition

Section 174 sets the tax treatment of research and experimental (R&E) expenditures. For tax years beginning after 2021 and before 2025, domestic R&E had to be capitalized and amortized over five years, using a midpoint convention, and foreign R&E over 15 years. Software development costs were treated as R&E. Public Law 119-21 added section 174A, which lets a taxpayer deduct domestic R&E paid or incurred in tax years beginning after December 31, 2024, or elect to amortize it over at least 60 months. Foreign R&E is still amortized over 15 years. Rev. Proc. 2025-28 explains how to treat amounts capitalized for 2022 through 2024, including an option to deduct the unamortized balance in one year or over two, and a retroactive election for eligible small businesses.

Why it matters in an audit or review

The rules drive current tax, the deferred tax asset for capitalized costs, and the book-tax reconciliation. Auditors test which costs management treated as R&E, such as wages and software, and whether the transition election was made and reflected.

Example

Illustrative: a company capitalized $600,000 of domestic R&E in 2023. Amortization was $600,000 / 5 x 0.5 = $60,000 in 2023 and $120,000 in 2024, leaving $420,000. A two-year election deducts $210,000 in each of 2025 and 2026.

Common mistakes

  • Applying 174A to foreign research.
  • Forgetting that the deferred tax asset reverses as the balance is deducted.

Sources

  • Public Law 119-21 (2025), section 70302, adding Internal Revenue Code section 174A
  • IRS, Revenue Procedure 2025-28 (Internal Revenue Bulletin 2025-38): https://www.irs.gov/pub/irs-drop/rp-25-28.pdf
  • FASB ASC 740-10-25, Recognition of income taxes

Definitions paraphrase AICPA and FASB guidance; read the standard itself before relying on a requirement. Example figures are illustrative. This page is guidance, not professional advice. Report an error

Standards

IRC 174IRC 174AASC 740

Related terms

  • Book-tax differences
    Book-tax differences arise when GAAP income differs from taxable income because of timing items that reverse and permanent items that never do, reconciled on Schedule M-1 or M-3.
  • Deferred tax assets and liabilities
    Deferred tax assets and liabilities capture the future tax effects of temporary differences between book and tax bases, measured at enacted tax rates under ASC 740 and classified as noncurrent.
  • Capitalization vs expensing
    Capitalizing records a cost as an asset and depreciates it over its useful life, while expensing charges it to income immediately; ASC 360 and entity policy distinguish betterments from repairs.

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