Code Sec. 174:
Research and Experimental expenses incurred in the years starting after 12/31/2021 must be capitalized and amortized over 5 and 15 years for US and foreign research respectively. Taxpayers must look at where the activities are performed to determine whether the corresponding expenditures are attributable to foreign research.
There is a mid-year convention for amortization in year one – that is amortization is ½ of the usual amount, as all the costs are assumed to be incurred on July 1st of that tax year, the mid-point.