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               Researh Sevice






Section 174 and Investment in Research and

Development



August 10, 2020

In determining their taxable income, companies are allowed to deduct all ordinary and necessary expenses
they pay or incur in generating gross income. Those expenses can be current (purchases of inputs with
useful lives of less than one year, such as materials and labor compensation) or capital (purchases of
assets with useful lives longer than one year, such as patents and computer systems). Current expenses are
written off in the year when they are paid or incurred. Capital expenses, by contrast, are written off over
the period when acquired tangible and intangible assets lose economic value through amortization or
depreciation allowances.

Since 1954, companies engaged in research and development (R&D) have been allowed to deduct in full
certain R&D expenses in the year when they were paid or incurred when calculating their taxable income.
This treatment is known as expensing and is allowed for qualified research expenses (QREs) related to
domestic and foreign research under Internal Revenue Code (IRC) Section 174(a).
The following research expenses qualify for expensing: (1) wages and salaries of researchers, (2)
materials and supplies used in qualified research, and (3) the costs of operating and maintaining research
facilities (e.g., rent, utilities, and insurance). Each expense is treated as a current expense under IRC
Section 162(a). Spending on equipment and buildings used to perform research must be capitalized and
recovered through claiming the appropriate depreciation allowances.
Companies investing in R&D have two options for capitalizing QREs and recovering them through
amortization over 5 or 10 years. IRC Section 174(b) allows companies to capitalize QREs and amortize
them over a period of 5 years, beginning with the month when a company first realizes benefits from an
R&D investment. (Amortization involves deducting the same amount in each year of an amortization
period, until the original cost of an asset has been fully recovered.) IRC Section 59(e) allows companies
to amortize QREs over 10 years, starting with the year when the expenditures were paid or incurred.

Impact of P.L. 115-97

No major change was made in IRC Section 174 between 1954 and the enactment of the 2017 tax revision
(P.L. 115-97, also known as the Tax Cuts and JobsAct or TCJA). The TCJArepealed the option to


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