MASSIE Services

174 Assistance

Developing your new capitalization process.


At MASSIE, we are uniquely qualified to assist clients in addressing section 174 classification. Our R&D experts can step in and work with you in every type of 174 matter, including preparing analysis, creating work plans and workbooks, and drafting memorandums in support of your capitalization methodology.

As a provider of R&D tax credit services to Fortune 500 companies, MASSIE is experienced in dealing with 174 issues. Whether you are just starting to address 174, or have been working at it for the past year, MASSIE is your trusted advisor in this area. We can give you peace of mind knowing your issues are being handled by industry experts.

What is the process like?

We start any 174 matter with the end in mind, which is to assist you in generating quality workpapers that are easy to follow and explain. We start our process with a phase we call Architecture and Analysis. During this phase, MASSIE will seek out guidance from the Company’s finance team to learn more about how R&E costs are captured and budgeted for future periods.

MASSIE requests financial statement workpapers, ASC 730 workpapers, and other documents available to perform a detailed review as part of understanding how you operate. The MASSIE team will prepare a 174 Matrix to include a summary of section 41 QREs (where available) and potential adjustments for section 174 eligible costs.

With any client facing 174 capitalization, MASSIE will work with you to determine whether costs are reasonable to classify as 174. We have guided countless clients through this process, and while many issues have not been addressed by the IRS yet, we do expect some FAQs or other guidance to come out soon. In the meantime, MASSIE is working with legal experts at firms like Sidley Austin, Morgan Lewis, and Ivins Philips, to give you comfort that decisions we make together can be reviewed by additional legal relationships we have in Washington.

At MASSIE, we take a very thoughtful approach to 174. We want to assist you to make sure we are coming up with a repeatable process and something that is simple to execute.

“My Company has been working with MASSIE R&D for the last 4 years. Given the technical nature to support our R&D tax credit calculations, we needed to use an external firm to assist us in maximizing our credits, both for US federal and the State of Georgia purposes. There are many accounting and specialty tax firms out there to choose from but making the decision to work working with MASSIE has been the right choice for us.”

Judd Schmid
Vice President – Corporate Controller

"This is our second year with MASSIE We've worked with other firms in the past, but our first year with MASSIE made a tremendous change in the process improvement of how we gather R&D data and support to sustain in the audit. This year we added the use of Microsoft Teams, which in combination with MASSIE process made this year's R&D study even more efficient and smooth to the point that we were a few months before the schedule of completing the study."

Yana Brez
Sr. Manager Tax
Rehrig Pacific Company
2020 - 2023
Repeat Honoree
Financial Times
America's Fastest Growing Companies
2019 - 2023
Repeat Honoree
Inc. 5000
America's Fastest Growing Private Companies
2022 - 2024
Platinum Sponsor
TEI (Tax Executives Institute)

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