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Section 174 permits taxpayers to currently deduct research and experimental expenditures. Beginning after December 31, 2021, section 13206 of Public Law 115-97 (TCJA section 174), will require taxpayers to amortize specified research or experimental expenditures ratably over a 5-year period (or a 15-year period in the case of specified research and experimental expenditures that are attributable to foreign research), beginning with the midpoint of the taxable year in which the specified research or experimental expenditures are paid or incurred. Further, any amount paid or incurred in connection with the development of any software shall be treated as a research of experimental expenditure.