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Tax & Compliance

Section 174 and 174A for Startups in 2026: R&D Expensing Is Back

Written by Aparna Devalla

Curated by Rubric Financial

Last updated

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Section 174 in 2026: The Short Answer

  • For tax years beginning after December 31, 2024, new Section 174A (added by the One Big Beautiful Bill Act, signed July 4, 2025) lets startups deduct domestic research and experimental costs, including US software development, in the year they are paid or incurred.
  • Foreign research costs stay under Section 174 and must still be capitalized and amortized over 15 years, so where engineers sit still changes your tax bill.
  • Domestic amounts you capitalized in 2022-2024 can be deducted in full on the 2025 return or split evenly across 2025 and 2026 (Rev. Proc. 2025-28), or you can keep amortizing them.
  • Taking the R&D credit now reduces the Section 174A deduction by the credit amount, unless you elect the reduced credit under Section 280C(c), which claims 79% of the credit and keeps the full deduction. Ask your CPA to model both for your profile.

About the author

Aparna DevallaCPA

Head of Tax & Accounting

CPA and Head of Tax & Accounting at StartupCFO. Specializes in multi-state tax compliance, R&D credits, and GAAP-compliant books for venture-backed startups.

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