Will Section 174 Allow Full Expensing of SWE Salaries for R&E in 2025?
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2026
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To resolve to "YES," legislation or regulatory guidance must be enacted or clarified that allows businesses to fully expense software engineer salaries related to research and experimental (R&E) activities in the same year they are incurred, rather than amortizing these expenses over a five-year period. This change would mean that SWE salaries tied to R&D projects can be immediately deducted from taxable income, restoring the pre-2022 treatment under Section 174 before the Tax Cuts and Jobs Act (TCJA) imposed amortization requirements.

The revision does not have to apply to the 2025 tax year.

https://open.substack.com/pub/pragmaticengineer/p/the-pulse-will-us-companies-hire

https://www.perplexity.ai/search/c86e815d-210a-4677-841d-0caecdef9839

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