TCJA forces 5-yr (US) / 15-yr (foreign) amortization of R&D — plan expense timing carefully.
TCJA (effective 2022) requires capitalization and amortization of R&D — 5 years US-based, 15 years foreign-based. Massive cash-flow hit for software/tech/biotech. Planning moves: shift R&D onshore (5 vs 15 yr), reclassify what's truly §174 vs §162 (only qualifying research), pair with §41 R&D credit (still allowed on §174-capitalized). Congress has repeatedly proposed reversal — model both scenarios.
Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.
Move trademarks/patents to NV/DE holdco, license back to opco, deduct royalties at state level.
Individual inventor selling patent gets LTCG treatment regardless of holding period.
Buy music catalogs at 8–15x annual royalties — 6–12% cash yield + upside.
Sell forward-flow of your royalties for a lump sum — David Bowie's original playbook.
Own your brand personally, license to your C-corp for arms-length royalty.
Get 6–14% credit on qualified R&D wages, supplies, contract research — plus state credit stack.
Sell franchise rights: retained significant power = ordinary income; full transfer = cap gains.
Cost-share IP dev between US parent + foreign sub — future IP owned by low-tax jurisdiction.