; but for purposes of this section allowances under section 167, and allowances under section 611, shall be considered as expenditures. (2) Exploration expenditures This section shall not apply to any expenditure paid or incurred for the purpose of ascertaining the existence, location, extent, or quality of any deposit of ore or other mineral (including oil and gas). (3) Software development For purposes of this section, any amount paid or incurred in connection with the development of any software shall be treated as a research or experimental expenditure. (f) Termination (1) In general This section shall not apply to amounts paid or incurred in taxable years beginning after December 31, 2025. (2) Change in method of accounting In the case of a taxpayer’s first taxable year beginning after December 31, 2025, paragraph (1) (and the corresponding application of section 174) shall be treated as a change in method of accounting for purposes of section 481 and— (A) such change shall be treated as initiated by the taxpayer, (B) such change shall be treated as made with the consent of the Secretary, and (C) such change shall be applied only on a cut-off basis for any domestic research or experimental expenditures paid or incurred in taxable years beginning after December 31, 2025, and no adjustment under section 481(a) shall be made. . (c) Coordination with certain other provisions (1) Research credit (A) Section 41(d)(1)(A) is amended by inserting or domestic research or experimental expenditures under section 174A after section 174 . (B) Section 280C(c)(1) is amended to read as follows: (1) In general The domestic research or experimental expenditures otherwise taken into account under section 174 or 174A (as the case may be) shall be reduced by the amount of the credit allowed under section 41(a). . (2) AMT adjustment Section 56(b)(2) is amended by striking 174(a) each place it appears and inserting 174A(a) . (3) Optional 10-year writeoff Section 59(e)(2)(B) is amended by striking section 174(a) (relating to