Delaying R&D Amortization Costs Less but Generates Little Economic Benefit Compared to Full Cancellation

Federal Tax

Starting next year, firms will need to amortize their research and development (R&D) expenses over five years rather than immediately deduct them from taxable income, a policy change designed to raise federal tax revenue in the short term. As policymakers decide on the future of this scheduled tax change, one option would be to delay the amortization of R&D expenses for four years until 2026. Within the ten-year budget window, a four-year delay would cost about $100 billion less than canceling amortization outright, but it would not increase long-run economic growth.

Cancelling R&D amortization outright would reduce federal revenue by about $131 billion between 2022 and 2031, while increasing long-run GDP and American incomes by 0.1 percent. Delaying the amortization until 2026, on the other hand, would cost about $33.6 billion, $100 billion less than cancellation, over those ten years and not increase long-run GDP.

Revenue Effect of Delaying R&D Amortization Until 2026
  2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2022-2031
Conventional -$40.6 -$26.0 -$16.3 -$10.6 -$5.2 $29.9 $17.5 $10.0 $5.8 $1.8 -$33.6

Source: Tax Foundation General Equilibrium Model, July 2021

While delaying amortization would be less expensive over the budget window, it would not increase long-run GDP because temporary tax policy changes do not affect long-run incentives. Temporary tax policy can change the timing of investment decisions but not the long-run after-tax return to investment, which means that the long-run size of the economy is not affected.

There is also a risk that R&D expensing becomes an ongoing “tax extender,” creating uncertainty about the tax treatment of R&D as businesses make investment decisions.

While extending the full deduction of R&D expenses until 2026 may be preferable to allowing amortization to go forward in 2022, a superior option for economic growth and the stability of the tax code would be to cancel the upcoming amortization of R&D expenses permanently.

Modeling the Timing of R&D Deductions and Impact on Federal Revenue

Switching from full expensing for R&D costs to five-year amortization temporarily limits the amount of deductions businesses can take. This raises the amount of baseline revenue, and this revenue is one of the reasons R&D amortization was included in the Tax Cuts and Jobs Act (TCJA). Delaying the switch to amortization delays this higher revenue and has a somewhat counterintuitive interaction with the current law baseline.

Under the delay, between 2022 and 2026, firms would continue taking immediate deductions instead of amortizing them over five years. That would reduce business taxable income and tax liability in those years, lowering federal revenue. Between 2027 and 2031, firms would begin amortizing deductions and that would increase business taxable income and tax liability, raising federal revenue.

The table below illustrates the timing difference of the delay against the backdrop of the current law baseline.

Imagine a firm making $100 of R&D investment each year. The cost of this investment is fully deductible in 2021. Under current law, starting in 2022, just one-fifth of the investment, or $20, is deductible each year. As new investment is made each year, one-fifth is deductible, meaning in 2023, the firm would take a total of $40 of deductions (reflecting one-fifth of 2022 investment plus one-fifth of 2023 investment). The pattern continues until the deductions for the 2022 investment are completed in 2026, at which point the total deductions allowed each year would level off. Total deductions each year would reflect one-fifth of total investment from the current year and the four years prior.

We can compare the deductions allowed each year under the current law baseline to the deductions allowed each year if amortization is delayed to see how the timing of deductions would change under the latter scenario.

If amortization were delayed, more deductions would be allowed earlier in the budget window, reducing federal revenue from 2022 to 2026, as shown in table 1. For example, in 2023 deductions would total $40 under current law, but $100 if amortization were delay. After amortization begins in 2026, the same phase-in of deductions occurs over five years, which increases federal revenue. For example, in 2028, deductions would have already built back up to $100 under current law but would only be $60 under the delay option.

In the long run, however, both options result in the same annual revenue effect—from the perspective of the federal budget, this is simply a short-term shift in the timing of deductions.

Illustrating How R&D Tax Deductions Change Under Current Law and Delaying Amortization by 4 Years
  2022 2023 2024 2025 2026 2027 2028 2029 2030 2031
Total annual R&D investment $100 $100 $100 $100 $100 $100 $100 $100 $100 $100
Total annual deductions under current law (5-Year amortization starting in 2022) $20 $40 $60 $80 $100 $100 $100 $100 $100 $100
Total annual deductions when 5-year amortization is delayed until 2026 $100 $100 $100 $100 $20 $40 $60 $80 $100 $100
Difference in the value of R&D deductions under amortization delay $80 $60 $40 $20 -$80 -$60 -$40 -$20 $0 $0

Source: Author calculations. Note: The nominal value of the R&D investment and deductions are not adjusted for inflation.

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