Section 174 mandates the capitalization of specified research or experimental expenditures (SRE), which includes a broad range of costs related to development. Listen as Tax Credits & Incentives Advisory Leader Martin Karamon, Director Vivian Kohrs and Senior Manager Bryan Weems discuss why it’s vital to evaluate intercompany intellectual property (IP) agreements and contracts for research and development (R&D) performed on behalf of others overseas.      

Tune in to learn more about:  

• How to prevent double capitalization 
• The potential impact of Section 174 when structuring an intercompany IP agreement  
• The rights or risk stipulation related to R&D activity 

Listen to other episodes in our Global Tech Tax Matters podcast series created for technology companies either conducting business in multiple countries or considering international expansion: 

• How to Protect Your Intellectual Property Abroad and Minimize Tax Liabilities
• From Outbound to Inbound: A Tech Company’s Guide to Expanding Globally (Part One – Outbound Transactions)
• From Outbound to Inbound: A Tech Company’s Guide to Expanding Globally (Part Two – Inbound Transactions) 

Related Guidance 

• Section 174 New Requirements and Its Impact on Technology Companies
• How To Plan for Global Tax Minimization
• Section 174 Research & Software Development Costs – A Guide to Compliance
• Global Intellectual Property Tax Planning