> there shall allowed as a deduction any domestic research and experimental expenditures which are paid or incurred by the taxpayer in the current taxable year
AFAIK, there was no domestic vs. foreign R&D distinction in section 174 before.
There was a domestic vs foreign distinction in the TCJA, passed in 2017, which took effect in 2022:
> 174 to require taxpayers to amortize specified R&E expenditures ratably over a five-year period for domestic expenditures and a 15-year period for specified R&E expenditures attributed to foreign research
There was a domestic vs foreign distinction in the TCJA, passed in 2017, which took effect in 2022:
> 174 to require taxpayers to amortize specified R&E expenditures ratably over a five-year period for domestic expenditures and a 15-year period for specified R&E expenditures attributed to foreign research
https://www.journalofaccountancy.com/issues/2022/nov/amortiz...