26 USC 174 - Amortization of research and experimental expenditures

U.S Code last checked for updates: Sep 26, 2025

§ 174.

Amortization of research and experimental expenditures

(a)

In general

In the case of a taxpayer’s foreign research or experimental expenditures for any taxable year—

(1)

except as provided in paragraph (2), no deduction shall be allowed for such expenditures, and

(2)

the taxpayer shall—

(A)

charge such expenditures to capital account, and

(B)

be allowed an amortization deduction of such expenditures ratably over the 15-year period beginning with the midpoint of the taxable year in which such expenditures are paid or incurred.

(b)

Foreign research or experimental expenditures

(c)

Special rules

(1)

Land and other property

(2)

Exploration expenditures

(3)

Software development

(d)

Treatment upon disposition, retirement, or abandonment

(Aug. 16, 1954, ch. 736, 68A Stat. 66; Pub. L. 94–455, title XIX, §§ 1901(a)(30), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1769, 1834; Pub. L. 97–248, title II, § 201(d)(9)(B) formerly § 201(c)(9)(B), Sept. 3, 1982, 96 Stat. 420, renumbered § 201(d)(9)(B),

cite as: 26 USC 174