26 U.S. Code § 174 - Amortization of research and experimental ...
State conformity or decoupling from Sec. 174 and new Sec. 174A, enacted by the law known as the One Big Beautiful Bill Act, complicates the treatment of research and experimental expenditures.
New IRS procedures in accordance with the One Big Beautiful Bill Act (OBBBA) give businesses the opportunity to unlock tax savings and simplify compliance around domestic research and experimentation expenditures under section 174 (research costs).
Code Sec. 174, below, as amended by P.L. 115-97, applies to amounts paid or incurred in tax years beginning after . The version of Code Sec. 174 that is applicable on or before , is available here
Understand the R&D tax credit and Section 174 treatment of research expense deductions, including current rules for expensing and amortization.
174 (number) ... 174 (one hundred [and] seventy-four) is the natural number following 173 and preceding 175.
Research or experimental expenditures which are neither treated as expenses nor deferred and amortized under section 174 must be charged to capital account. The expenditures to which section 174 applies may relate either to a general research program or to a particular project.
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Congress repealed Section 174 amortization, restoring R&E expensing. See how the 2025 tax law changes impact your deductions and R&D tax strategy.