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Re:OBBB signed: Reinstates immediate expensing for U.S.-base... by tareqak on Saturday July 05, 2025 @02:19AM (#44470486)
Page 301

> 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.

Re:OBBB signed: Reinstates immediate expensing for U.S.-base... by Thorrez on Saturday July 05, 2025 @03:33AM (#44470795)
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...