These are questions for a tax attorney.
If you are a pure software company (no hardware or other activities) your options are rather limited.
Also, as I said in other posts, at year six you reach steady-state and are amortizing the full amount every year. Example:
amortization for each year
R&D year 1 year 2 year 3 year 4 year 5 year 6
year 1 1,000,000 100,000 200,000 200,000 200,000 200,000 100,000
year 2 1,000,000 100,000 200,000 200,000 200,000 200,000
year 3 1,000,000 100,000 200,000 200,000 200,000
year 4 1,000,000 100,000 200,000 200,000
year 5 1,000,000 100,000 200,000
year 6 1,000,000 100,000
total amortization: 100,000 300,000 500,000 700,000 900,000 1,000,000
Not ideal, of course, but if you are not a "flash in the pan" company, at year 6 it feels like this rule doesn't exist, other words, you are amortizing the full $1MM every year. The TVM on the deductions you could not take until steady-state is reached is part of the hit you take. The other is taxes on profits from operations during the early years.
Most companies don't have profits rise exponentially during the first few years, so it might not be too bad. Also, there are many ways to mitigate this. For example, section 179, which allows businesses to deduct the full purchase price of qualifying equipment and software in the year it's put into service, rather than depreciating it over several years. In other words, instead of paying taxes on your profits, use that money to buy GPU's computers, tools or whatever you might need. Easy.
A tax attorney is essential if you want to minimize tax liabilities intelligently and within the bounds of the law.
But, yes, 174 needs to go back to full annual deductions.