Feature Article

Section 174 – Research and Development Credit Revised Regulation Analysis

In 1954, Congress enacted a temporary research and development (R&D) credit codi!ed by Internal Revenue Code (IRC) Sec. 174. "e purpose of the credit is to encourage inventors and companies to pursue research and development of new technologies. Although simple in theory, there have been problems with its implementation. Critics have argued that the credit is confusing as to which expenses qualify as “quali!ed research expenses.”1Darshan Wadhwa, CPA, and John Leavins, CPA