Introduction
In recent years, the landscape of corporate taxation in the United States has undergone significant changes, particularly with the introduction of the Tax Cuts and Jobs Act (TCJA) in 2017. Section 174 of the Internal Revenue Code, which significantly changed how companies report their research and development (R&D) expenses, is among the most significant aspects of this law. These changes have generated considerable confusion and uncertainty among corporate tax departments, necessitating a closer examination of what qualifies as R&D expenditures and how they should be handled for tax purposes.
Historically, businesses had the option to immediately deduct R&D costs or amortize them over a period of at least five years. This flexibility allowed companies to manage their tax liabilities effectively, which was particularly beneficial for startups and businesses heavily invested in innovation. However, with the implementation of Section 174, the rules have shifted dramatically. Starting with tax years beginning after December 31, 2021, businesses are required to capitalize R&D expenditures and amortize them over a period of five years, or fifteen years for certain foreign research expenditures [4][7].
This new requirement has raised several essential questions for taxpayers. What types of costs qualify as R&D expenditures? How should businesses categorize and report these expenditures? And what strategies can companies employ to navigate this new landscape effectively? Understanding the nuances of Section 174 is crucial for businesses that engage in R&D activities, as it directly impacts their tax obligations and overall financial health.
Section 174 defines R&D expenditures broadly, encompassing both internal labor costs and external services, as long as the work is performed within the United States. Additionally, materials and supplies consumed during the R&D process are also included [3]. However, not all expenses related to R&D qualify for this treatment, complicating the tax planning process for many companies. For instance, expenses related to market research or quality control do not meet the criteria for capitalized R&D costs, which can lead to increased tax bills for businesses that fail to distinguish between qualifying and non-qualifying expenditures [2][6].
The complexity of complying with the new Section 174 rules has led many companies to seek advice from tax professionals to ensure they are maximizing their credits and deductions while remaining compliant with the IRS regulations. The obligation to capitalize and amortize R&D costs not only changes the financial reporting landscape but also impacts cash flow and investment decisions. Businesses must now consider how these changes affect their strategies for funding and managing innovation
Chapter 1: Introduction to Section 174 — Historical Context and Legislative Background
The Internal Revenue Code (IRC) Section 174, which governs the treatment of research and experimental (R&E) expenditures, has undergone significant changes since its inception. To understand these changes, it is essential to consider the historical context and legislative background that led to the current framework. This chapter delves into the evolution of Section 174, particularly focusing on the landmark Tax Cuts and Jobs Act (TCJA) of 2017 that introduced radical modifications to how businesses account for R&E costs.
Historically, Section 174 provided taxpayers with the option to either deduct their R&E expenditures in the year they were incurred or to amortize these costs over a period of at least 60 months. This flexibility allowed companies to optimize their tax liabilities in alignment with their financial strategies, thus encouraging innovation and investment in research and development activities. For many decades, this provision incentivized businesses to engage in R&D, as immediate deductions could significantly reduce taxable income and improve cash flow [1][7].
However, the passage of the TCJA marked a pivotal shift in the treatment of R&E expenditures. For tax years starting after December 31, 2021, the TCJA got rid of the option to deduct R&E costs right away. Instead, these costs had to be capitalized and spread out over five years (or fifteen years for some foreign research costs). This change has generated considerable confusion and concern among corporate tax departments, as it alters the financial landscape for businesses heavily invested in R&D [1][3][4].
The motivation behind these changes can be traced back to a broader legislative agenda aimed at simplifying the tax code and closing perceived loopholes that allowed significant tax avoidance. Supporters of the TCJA said that making R&D costs capitalized would make the tax system more fair by lining up the timing of deductions with when the benefits of those costs were realized. Critics, however, contend that this shift could disincentivize innovation, particularly among startups and small businesses that rely on immediate deductions to reinvest in growth and development [2][6].
The implications of Section 174 are not merely academic; they have real consequences for businesses across various sectors. Under the new rules, companies have to figure out which costs qualify, which can be hard because only certain costs, like labor and materials directly related to R&D activities, can be capitalized [3, 7]. This necessitates a thorough understanding of both the legal definition of R&E expenditures and the administrative requirements for compliance.
The change in Section 174 from a flexible deduction system to a mandatory capitalization system shows a big change in how the U.S. taxes research and development. This chapter lays the groundwork for a more in-depth look at the current rules under Section 174, the types of expenses that are allowed, and the approaches companies can take to best deal with the new environment. Understanding these elements is crucial for any corporate tax specialist or business leader looking to harness the full potential of R&D tax incentives in the current economic climate.
Chapter 2: Key Changes Under the Tax Cuts and Jobs Act — Capitalization and Amortization Requirements
The Tax Cuts and Jobs Act (TCJA), enacted in December 2017, brought about significant changes to various aspects of the tax code, one of which is Section 174, which specifically addresses the treatment of research and experimental (R&E) expenditures. These changes have introduced new capitalization and amortization requirements that affect how businesses report their R&E costs for tax purposes. Understanding these requirements is crucial for companies engaged in research and development activities, as it directly impacts their financial reporting and tax strategies.
Historical Context
Prior to the TCJA, Section 174 allowed companies to immediately deduct their R&E expenditures in the year they were incurred or amortize them over a period of at least 60 months. This flexibility was beneficial for businesses as it enabled them to manage their tax liabilities in a manner that suited their financial planning. However, the TCJA changed this approach by mandating that all R&E expenditures incurred after December 31, 2021, be capitalized and amortized over a period of five years for domestic expenses and 15 years for foreign R&E expenses [1][7].
New Capitalization Requirements
Under the new rules established by the TCJA, businesses can no longer fully deduct R&E costs in the year they occur. Instead, they are required to capitalize these expenditures. This means that companies must record their R&E expenses as assets on their balance sheets rather than as immediate deductions against their income. The costs must then be amortized over the specified periods—five years for domestic research and fifteen years for research conducted outside the United States [4][6].
The shift to mandatory capitalization has raised concerns among corporate tax departments regarding cash flow implications and increased complexity in tax compliance. Companies now face the challenge of accurately tracking and reporting these expenditures, which can involve significant administrative overhead [2][3].
Amortization of R&E Expenditures
Once R&E expenditures have been capitalized, businesses must amortize these costs ratably over the applicable period. For most companies, this means spreading the cost over five years. However, the amortization begins with the midpoint of the taxable year in which such expenditures are paid or incurred. As a result, in the first year of amortization, only half of the annual amount is deducted.
For example, if a company incurs R&E costs in 2022, in 2022 the company will deduct only 50% of the annual amortization amount. This means that the full amortization period will last 5.5 years (instead of 5 years) or 15.5 years (instead of 15 years) for expenditures related to foreign research [10]
While this new structure may seem straightforward, it introduces a level of complexity in tax planning. Companies must ensure that they correctly categorize their expenditures as R&E and determine the appropriate amortization schedule. This requirement can often lead to disputes with tax authorities regarding the classification of specific costs, particularly in cases where the line between R&E and other business expenses is not clear [1][8].
Implications for Businesses
The implications of these changes are significant for businesses, particularly startups and small to mid-sized enterprises that rely heavily on R&D activities. The inability to immediately deduct R&E expenses can lead to a temporary cash flow crunch, as companies may face higher taxable income in the years when they are incurring significant research costs [3][6].
Moreover, businesses must also consider the strategic aspects of their tax planning. They may need to reevaluate how they categorize their costs and explore ways to optimize their deductions through careful planning. For instance, companies can benefit from distinguishing between R&E and other operational costs, as this could allow them to maximize their potential tax credits under different sections of the tax code [2][4].
There are big changes in how taxes are calculated for research and development costs because of the Tax Cuts and Jobs Act. These changes affect how these costs are capitalized and amortized. Businesses must adapt to these new requirements to ensure compliance and optimize their tax positions in light of the mandated changes. Understanding the intricacies of Section 174 is essential for companies engaged in R&E, as these changes can have profound effects on their financial health and strategic planning.
Chapter 3: Defining Research and Experimental Expenditures — What Qualifies Under Section 174
In the realm of corporate taxation, understanding what qualifies as research and experimental (R&E) expenditures is crucial, especially under the guidelines set forth by Section 174 of the Internal Revenue Code. This section underwent significant changes following the Tax Cuts and Jobs Act (TCJA) enacted in 2017, which reshaped how businesses account for their R&E costs.
Overview of Section 174
Historically, Section 174 allowed businesses to either deduct R&E expenditures immediately or amortize them over a period of at least 60 months. This flexibility enabled companies to optimize their tax liabilities effectively, adapting their financial strategies based on immediate cash flow needs [1]. However, starting from tax years beginning after December 31, 2021, the rules changed dramatically. Companies are now required to capitalize R&E expenditures and amortize them over a five-year period for domestic research or a 15-year period for expenditures related to foreign research [4][6].
What Qualifies as R&E Expenditures?
While many costs can qualify under Section 174, certain expenditures are explicitly excluded. For instance, costs related to marketing, quality control, or routine testing of products do not meet the criteria for R&E expenditures. Additionally, expenses incurred after a product has entered commercial production are generally not considered qualifying R&E costs [2][6].
Implications of the New Rules
The shift from immediate deduction to mandatory capitalization and amortization poses significant implications for businesses. This change can affect cash flow, as companies can no longer deduct R&E costs in the year they are incurred. Instead, they must plan for the amortization of these costs over several years, which can complicate financial forecasting and tax planning strategies [7]. Companies must now be more diligent in categorizing their expenditures to ensure compliance with Section 174 guidelines and to maximize their potential tax benefits.
To navigate these complexities, organizations may benefit from consulting tax specialists who are well-versed in the nuances of Section 174. This expertise can aid in accurately identifying qualifying expenses and ensuring proper documentation, thus minimizing the risk of non-compliance [1][4].
Businesses that want to use their research activities to get tax breaks while still following the rules need to make sure they understand these definitions and what they mean for R&E expenditures under Section 174.
Chapter 4: Implications for Businesses — Tax Liability, Compliance Challenges, and Strategic Considerations
The landscape of business taxation has changed significantly due to new regulations introduced by the Tax Cuts and Jobs Act (TCJA) of 2017, particularly with the implementation of Section 174. This section mandates that businesses capitalize their research and experimental (R&E) expenditures rather than fully deduct them in the year they are incurred. This shift has far-reaching implications for businesses of all sizes, affecting their tax liabilities, compliance efforts, and strategic planning.
4.1 Tax Liability Implications
Traditionally, businesses could deduct R&E expenses immediately, providing a substantial tax benefit in the year those costs were incurred. With the new requirements under Section 174, companies must now capitalize these costs and amortize them over five years (15 years for foreign R&E expenditures) [1]. This change can lead to higher taxable income in the short term, which subsequently increases tax liabilities during the initial years following the adoption of the new rules.
For startups and smaller businesses, the immediate tax impact is particularly severe, as they often rely heavily on R&D to innovate and grow. The inability to deduct these costs upfront can limit cash flow and hinder growth initiatives. The TCJA’s alterations mean that only specific costs qualify for R&D tax credits, potentially leaving many businesses at a disadvantage if they cannot accurately categorize their expenditures [3].
4.2 Compliance Challenges
The transition to capitalizing and amortizing R&E costs introduces a series of compliance challenges for businesses. Firstly, companies must develop robust accounting systems to ensure accurate tracking and categorization of R&D expenses. The Internal Revenue Code (IRC) requires businesses to distinguish between eligible R&D expenditures and other operational costs, which demands meticulous record-keeping and accounting practices [4].
Moreover, the evolving guidelines surrounding Section 174 necessitate ongoing education and training for finance and tax departments. As noted by experts, tax liability under Section 174 can create uncertainty and increased tax bills for taxpayers engaged in R&D activities [6]. Consequently, businesses may need to invest in external consultancy or software solutions to navigate these new compliance requirements effectively.
4.3 Strategic Considerations
The implications of Section 174 extend beyond mere compliance; they also necessitate strategic adjustments. Businesses need to reevaluate their R&D strategies, considering how to optimize their expenditures to maximize tax benefits. For instance, categorizing costs into R&D and non-R&D buckets could be a viable tactic for mitigating tax impacts. Companies may also want to explore alternative funding sources or partnerships that can help offset the cash flow constraints imposed by the new tax liabilities [3].
Additionally, firms may need to assess their long-term investment strategies and consider how R&D fits into their broader business objectives. With the capitalized costs being spread over several years, companies must plan their cash flow more judiciously, ensuring they can sustain R&D initiatives while managing their overall financial health.
As businesses adapt to these changes, they should also stay informed about potential legislative developments that may alter Section 174 or introduce new incentives for R&D. Engaging with tax professionals and industry groups can provide valuable insights and help companies remain agile amidst ongoing changes in tax law [2][7].
In summary, the implications of Section 174 are profound and multifaceted, affecting tax liabilities, compliance requirements, and strategic planning for businesses engaged in research and development. Understanding these changes is essential for financial health and operational success in a competitive landscape.
Chapter 5: Future Outlook — Legislative Proposals and the Ongoing Debate Surrounding Section 174
The future of Section 174 of the Internal Revenue Code, particularly in light of ongoing legislative proposals, remains a topic of substantial debate among policymakers, tax professionals, and business leaders. Section 174 of the Tax Cuts and Jobs Act (TCJA), which was passed in 2017, requires that research and experimental costs be capitalized and amortized. This is different from the old system, which let businesses deduct these costs in the year they were incurred. This change has sparked numerous discussions regarding its implications for innovation, economic growth, and tax policy.
Legislative Proposals
Recent discussions in Congress have indicated a potential shift in legislative priorities with respect to Section 174. Some lawmakers are advocating for modifications that would revert to more favorable tax treatments for research and development (R&D) expenditures. There are plans to either get rid of the requirement that businesses must capitalize or give them more options. This is because the current rules make it hard for businesses, especially new and small ones, to deduct their costs quickly [1, 2].
These proposals reflect a broader recognition of the importance of R&D in driving economic growth and competitiveness. The current structure of Section 174 is seen by some as a deterrent to investment in innovation, as companies face higher upfront costs without immediate tax relief. Proponents of reform argue that reinstating the ability to fully deduct R&D expenses in the year they occur would incentivize businesses to increase their investment in innovative projects, ultimately benefiting the economy and job creation [3][4].
Ongoing Debate
The debate surrounding Section 174 is multifaceted, with various stakeholders presenting differing perspectives on its impact. Supporters of the existing framework argue that the amortization of R&D expenditures allows for a more stable and predictable tax revenue stream for the government. They contend that this approach encourages companies to evaluate their R&D investments more carefully, leading to more strategic and potentially fruitful expenditures [5][6].
Conversely, critics assert that the current rules disproportionately disadvantage smaller firms and startups that rely heavily on R&D to establish themselves. Many of these companies operate on tight margins, and the inability to deduct R&D expenses upfront can lead to cash flow issues and deter them from pursuing ambitious projects. This concern is particularly relevant in high-tech industries, where innovation is crucial for survival and growth [7][8].
Additionally, the impact of Section 174 on international competitiveness has become a focal point of discussion. As other countries continue to offer generous tax incentives for R&D, there is growing fear that the U.S. may fall behind in attracting and retaining innovative companies. The ongoing debate includes proposals to align U.S. tax policy more closely with international standards to foster a more competitive environment for domestic businesses [1][3][4].
As discussions evolve, the future of Section 174 will likely depend on a combination of political will, economic conditions, and a growing recognition of the essential role that R&D plays in fostering innovation. The ongoing debate about how best to support research and development will continue to shape the legislative landscape, and the decisions made in the coming years could have lasting implications for the U.S. economy and its global standing.
Chapter 6: Real-World Case Studies — Impact of Section 174 on Innovation
To illustrate the profound effects of the mandatory capitalization and amortization rules under Section 174, this chapter presents four in-depth case studies drawn from small businesses and startups facing significant tax liabilities on research expenditures. These examples are adapted from publicly shared accounts of how Section 174 has affected companies pursuing vital innovations in fields ranging from water treatment to pediatric medical devices. All case studies are sourced from a compilation by Eva Garland Consulting [9].
Case Study 1: XbyEL Technologies, Inc. (Mesa, AZ)
Company Overview
- Industry: Water treatment technology
- Focus: Developing electrochemical methods to destroy harmful PFAS chemicals in water, which affect over 100 million Americans and are linked to serious health conditions such as cancer and organ dysfunction.
- Funding: Primarily from National Science Foundation and U.S. Air Force grants.
- Employees: 4
Impact of Section 174
- Tax Liability: Due to the five-year amortization rules, the company’s 2022 R&D credits resulted in a $120,000 negative impact. Rather than receiving a tax benefit, the company now faces a $40,000 tax bill.
- Cash Flow Crisis: With a remaining runway of only 3–4 months, these unforeseen tax obligations threaten the company’s survival.
- Consequences:
- Possible staff reduction (from 4 employees) to reduce monthly costs.
- The company may not survive to see the future tax benefits of amortizing the R&D costs.
Key Takeaway: XbyEL’s situation underscores how Section 174 can burden cash-strapped startups, even those working on socially critical R&D projects. The inability to deduct R&D costs immediately has led to a severe cash flow shortfall.
Case Study 2: Dynamoid LLC (Oakland, CA)
Company Overview
- Industry: Science education software
- Focus: Building an immersive platform using virtual reality (VR) to facilitate science communication (“Magic School Bus”-style learning).
- Funding: Bootstrapped with revenue from contract work; also received a $260,000 NIH SBIR/STTR grant in 2022.
- Employees: 2 full-time
Impact of Section 174
- Tax Liability: Instead of showing a $30,000 loss on the 2022 Schedule K (and consequently receiving a refund), the founder now faces a personal tax bill of approximately $100,000 due to mandatory R&D cost capitalization.
- Personal Financial Strain: The founder’s salary (~$100,000 in 2022) in the San Francisco Bay Area is modest, and a large, unexpected tax bill jeopardizes essential expenses like childcare.
- Future Prospects:
- May have to negotiate a 5-year IRS payment plan of over $1,000 per month.
- Continual R&D could become untenable, risking the company’s closure even before it breaks even.
Key Takeaway: Dynamoid’s story highlights how Section 174’s amortization requirement can severely disrupt personal finances for an entrepreneur and threaten the continuity of a promising early-stage company.
Case Study 3: iNFixion Bioscience, Inc. (San Diego, CA)
Company Overview
- Industry: Biotechnology
- Focus: Researching treatments for Neurofibromatosis (NF1), a rare disease affecting 1 in 3,000 people in the U.S. (approximately 120,000 Americans).
- Funding: Exclusively from Federal NIH SBIR/STTR grants (no commercial revenue).
- Employees: 4 (2 PhDs, 1 lab assistant, 1 CEO), all dedicated to R&D.
Impact of Section 174
- Tax Liability: Despite having zero profit in 2022 based on GAAP accounting, iNFixion faces an $84,000 tax bill under the new Section 174 rules.
- Risk of Bankruptcy: The company does not have $84,000 in reserve, and without relief, bankruptcy may be the only option.
- Broader Effects:
- Approximately $2 million in NIH and DoD grants could be squandered if ongoing research is abruptly halted.
- A vital line of inquiry for a rare disease with limited treatment options could be abandoned, undermining patient communities hoping for a cure.
Key Takeaway: iNFixion’s case underscores how the Section 174 change can decimate early-stage biotech companies, threatening critical research funded by federal grants and potentially halting advancements for patients with rare diseases.
Case Study 4: Prapela (Portland, ME)
Company Overview
- Industry: Pediatric medical device technology
- Focus: Pioneering a mattress to help newborns breathe, with a unique vibration technology. Recognized with multiple awards, including two Breakthrough Device Designations from the FDA.
- Funding: Over $8 million in non-dilutive awards from NIH, state grants, and Johnson & Johnson.
- Regulatory Path: Pursuing FDA clearance for commercial sale.
Impact of Section 174
- Unexpected Tax Bills: Because of mandatory R&D cost capitalization, Prapela now owes both state and federal taxes.
- Funding Restrictions: The inability to use NIH grant funds for taxes results in a significant shortfall before FDA clearance.
- Threat to Innovation:
- Potentially derails a life-saving technology for opioid-exposed and preterm newborns.
- Years of clinical research and millions in grant funding could be lost if the company fails to meet its tax obligations.
Key Takeaway: Prapela’s experience illustrates how the Section 174 requirement can jeopardize even the most promising and publicly recognized innovations, especially when federal grant funds cannot be diverted to cover income tax liabilities stemming from R&D activities.
Case Study 5: Foreign Contractor Compliance Under Section 174
Company Overview
- Industry: IT and Software Development
- Focus: A Delaware-registered American company specializing in software development, working with foreign contractors to build proprietary technology.
- International Operations: Engages a team of 50 Polish developers operating as independent contractors.
- Regulatory Impact: Required to comply with new Section 174 rules regarding R&D expense capitalization for foreign-sourced work.
Impact of Section 174
- Unexpected Tax Burden: The company was previously deducting all R&D expenses immediately. The Section 174 amendments forced them to capitalize and amortize these costs over 15 years, increasing their taxable income and tax liability.
- Compliance Challenges: Additional tax forms (e.g., Form 3115 and Form 4562) were required, complicating financial reporting.
- Risk of IRS Audits: Any misallocation of expenses—whether mistakenly deducting capitalizable costs or misclassifying deductible expenses—posed a risk of penalties and audits.
Threat to Business Operations
- Financial Strain: With an unexpectedly high tax bill, the company faced a significant cash flow problem.
- Delays in Product Development: Higher tax obligations meant fewer funds were available to reinvest in software development.
- International Tax Complexity: Managing tax compliance across U.S. and Polish regulations added further complications, requiring expert financial review.
Key Takeaway
This case highlights the urgent need for companies working with foreign contractors to reassess their R&D accounting practices under Section 174. Without proactive tax planning, businesses risk compliance issues, increased financial strain, and potential disruptions to critical product development.
Case studies summary
These five case studies vividly demonstrate the challenges imposed by Section 174’s mandatory capitalization and amortization of R&D expenses. Early-stage companies and small businesses—often reliant on federal grants and lacking robust revenue streams—face immediate and severe cash flow crises. This financial strain can curtail innovation, delay critical research, or even lead to bankruptcy before the long-term tax benefits of amortization can be realized.
As policymakers continue to debate the future of Section 174, these real-world stories underscore the urgency for legislative or administrative relief. Without timely action, the U.S. risks stifling innovation and undermining the very startups and small businesses that fuel scientific progress and economic growth.
Conclusion
The transformation of Section 174—from allowing immediate deductions of research expenditures to requiring capitalization and multi-year amortization—marks a significant shift in U.S. tax policy. While intended to simplify the tax code and align the timing of deductions with the realization of benefits, these changes have introduced complex administrative requirements and potentially burdensome tax liabilities for businesses engaged in R&D. Startups and small enterprises, particularly those relying on grants and lacking significant revenue streams have been disproportionately affected. The cash flow constraints and planning challenges they face threaten not only their own viability but also the broader innovation ecosystem that depends on these companies’ breakthroughs.
The detailed case studies underscore the very real, sometimes dire, effects of Section 174 on startups working in critical areas such as water treatment, biotechnology, and pediatric medical devices. The examples highlight how these businesses—often solely funded by federal grants that cannot be used to pay taxes—face an unexpected tax burden at a stage when every dollar is crucial for sustaining R&D. As a result, many companies must consider staff reductions, pivot away from high-impact projects, or in the worst cases, file for bankruptcy.
Legislative discussions concerning Section 174 continue, with some lawmakers proposing reinstating or revising immediate R&D deductions. The outcome of these debates will significantly influence America’s competitive edge, as well as the capacity of its small businesses to innovate, hire, and grow. In the meantime, companies must navigate the complexities of mandatory capitalization, exercising meticulous documentation and accounting practices to ensure compliance and optimize available tax credits.
Ultimately, Section 174’s future remains uncertain. Yet, its current impact on cash flow and strategic planning for R&D-intensive ventures is both tangible and substantial. Stakeholders—from policymakers to tax professionals—must consider the innovation economy’s needs, seeking an approach that both upholds the integrity of the tax system and supports pioneering research across industries.
References
[1]. Section 174: Understanding Research & Development expenditures – Thomson Reuters Institute:
https://www.thomsonreuters.com/en-us/posts/tax-and-accounting/section-174-expenditures/
[2]. Section 174 – SRE Expenditures – Compliance Update & Practical Guide:
https://www.forvismazars.us/getattachment/415d7f29-be0b-4a98-81e2-60db76f754da/Section-174-CRE-Expenditures-Compliance-Update-and-Practical-Guide-Presentation-Materials.pdf
[3]. The Startup Guide to Section 174 | Rho:
https://www.linkedin.com/pulse/startup-guide-section-174-rhobusiness-lgate
[4]. IRC Section 174 | Internal Revenue Code (R&D Amortization):
https://www.taxnotes.com/research/federal/usc26/174
[5]. Cherry Bekaert • Tax Beat Podcast:
https://www.youtube.com/watch?v=vbS-Uz0p3xU
[6]. The Current State of R&D: Internal Revenue Code Section 174 and Other Updates:
https://104201.fs1.hubspotusercontent-na1.net/hubfs/104201/2024/The%20Current%20State%20of%20R&D.pdf?hsCtaTracking=90c56f0f-b733-42e3-bf12-12dca5f549fc%7C067ec66e-ba52-4704-870e-fe6466409935
[7]. Navigating the New Section 174 Rules: Amortizing R&E Expenditures:
https://www.brinkersimpson.com/blog/navigating-the-new-section-174-rules-amortizing-expenditures
[8]. IRC Section 174 vs. Section 41 Tax Credits for Manufacturers:
https://www.cbh.com/insights/articles/irc-section-174-vs-section-41-tax-credits-for-manufacturers/
[9]. Innovation Tax: Case Studies (Eva Garland Consulting):
https://www.evagarland.com/wp-content/uploads/2023/12/Innovation-Tax-Case-Studies-12.4.23.pdf
[10] Guidance on Amortization of Specified Research or Experimental Expenditures under Section 174
https://www.irs.gov/pub/irs-drop/n-23-63.pdf
