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Section 174: United States

Section 174 governs the deduction of research and experimental expenditure, a wider set of costs than the credit. How the 2022 amortisation rule and the 2025 restoration of immediate deduction for domestic research work, and how they interact with the credit.

United StatesLast reviewed 1 October 2026

Section 174 is the deduction rule for research and experimental expenditure; section 41 is the credit. The two are linked in both directions: a cost can only be a qualified research expense for the credit if it is eligible to be treated as research or experimental expenditure under section 174, and the credit reduces the section 174 deduction unless the reduced credit is elected. Section 174 also changed twice in four years, which has made it the more consequential of the two provisions for many companies.

What it is

Research or experimental expenditures are costs incurred in connection with the taxpayer's trade or business which represent research and development costs in the experimental or laboratory sense: costs of activities intended to discover information that would eliminate uncertainty about the development or improvement of a product. The definition is wider than the credit's: it includes all costs incident to the research, such as overhead, rent, depreciation on research equipment and the full cost of contractors, and the statute expressly treats software development costs as research or experimental expenditure.

PeriodDomestic researchForeign research
Tax years beginning before 2022Deduct in the year incurred, or elect to amortiseSame
Tax years beginning after 2021 and before 2025Capitalise and amortise over five years, starting at the midpoint of the yearCapitalise and amortise over 15 years
Tax years beginning after 2024Deduct in the year incurred under new section 174A, or elect to capitalise and amortise over not less than 60 monthsCapitalise and amortise over 15 years

Transitional relief accompanied the 2025 change: small businesses were allowed to apply the new rule retroactively to tax years beginning after 2021, and all taxpayers were allowed to accelerate the deduction of amounts still being amortised. The details of those elections are a matter for the taxpayer's advisor and the IRS procedures issued under the statute.

Who it applies to

Every taxpayer that incurs research or experimental expenditure, whether or not it claims the credit. Section 174 is not elective in its scope: research or experimental expenditures can be recovered only under section 174 or 174A; they may not be deducted under section 162. This caught many companies between 2022 and 2024, when software development costs that had always been expensed had to be amortised and taxable income rose while cash did not.

How it works

Scope. Identify the costs that are research or experimental expenditure: wages, contractor costs in full, supplies, overhead attributable to research, depreciation on equipment used in research, and software development. Costs of land and depreciable property themselves are not research or experimental expenditure, but the depreciation on them is.

Location. Domestic research is research conducted in the United States, Puerto Rico and US possessions; foreign research is everything else. The distinction decides whether a cost is deductible currently or amortised over 15 years.

Interaction with the credit. Section 280C(c) prevents a double benefit: unless the reduced credit is elected, the amount deductible (or capitalised) under section 174 is reduced by the amount of the research credit. The election under section 280C(c)(2) takes a smaller credit instead and leaves the deduction intact. The calculation page shows the reduced rates.

Consistency. Examiners compare the costs claimed for the credit with the costs treated under section 174. QREs should be a subset of section 174 costs; a company that claims the credit on wages it has not treated as research or experimental expenditure invites questions.

Worked example

Illustrative example. Ridgeline Software, a hypothetical company with a calendar year, spends US$2,000,000 on domestic software development in a year, of which US$1,500,000 are QREs, and earns a US$100,000 credit under the alternative simplified credit without the reduced credit election.

YearSection 174 treatmentDeduction in year oneEffect of the credit on the deduction
2024Amortise over five years from the midpointUS$200,000 (10% of US$2,000,000)Capitalised amount reduced by US$100,000; the reduction flows through the amortisation
2025 and afterDeduct currently under section 174AUS$2,000,000Deduction reduced by US$100,000 to US$1,900,000, or elect the reduced credit of US$79,000 and keep the full deduction

At a 21% corporate rate the two routes in 2025 give the same after-tax position: US$100,000 of credit less US$21,000 of tax on the lost deduction, or US$79,000 of credit. Companies with losses, state tax differences or other credits may find one route better than the other, which is why the election is computed rather than assumed.

Common questions

Does section 174 apply if we do not claim the credit? Yes. The scope rule applies to all research or experimental expenditure.

Are our overseas developers' costs deductible? Foreign research is amortised over 15 years whatever the year, and is excluded from the credit entirely.

Can we deduct the remaining 2022 to 2024 amortisation faster? The 2025 legislation provides elections for that; the mechanics depend on the taxpayer's size and the procedures the IRS issued, and are outside this general page.

Official sources

Educational content only, not tax advice. See the disclaimer.