
Section 174 R&D Expensing in 2026: How Software Startups Recover From the TCJA Capitalization Trap
OBBBA's new Section 174A restores immediate expensing for domestic R&D in tax years after December 31, 2024, and qualifying small businesses can amend 2022–2024 returns by July 6, 2026 to recover overpaid tax. A guide to the three coexisting Section 174 regimes, the Section 41 credit add-back, foreign 15-year amortization, and the statement in lieu of Form 3115.










