Section 174 usually is more of an issue for smaller/private companies. On the contrary, when I worked for a bigger company, we specifically tried to capitalize

Section 174 usually is more of an issue for smaller/private companies. On the contrary, when I worked for a bigger company, we specifically tried to capitalize as much software development costs as possible, because it makes the company look more profitable. We (all of the software engineers) hated this because, for an internet-facing company that does continuous deployment, bucketing "new work" into CapEx vs "maintenance" into OpEx is nearly impossible when you're just adding new features to an existing product over time.