![]() ![]() The TCJA also requires software development costs to be treated as SRE expenditures. The TCJA amended Section 174 by removing the option to expense SRE expenditures, instead requiring taxpayers to capitalize and amortize SRE expenditures over a period of five years (attributable to domestic research) or 15 years (attributable to foreign research), beginning with the midpoint of the taxable year in which the expenses are paid or incurred. 2023-24 to change their methods of accounting under Section 174 (see our prior story for more information on implementing the rules). ![]() Taxpayers that have not yet changed their method to comply with Section 174 may implement the rules of the notice by following the guidance in Section 7.02 of Rev. The IRS also intends to issue procedures for taxpayers to obtain automatic consent to change their method of accounting to comply with this notice, including procedures for taxpayers that have already changed their methods of accounting to comply with Section 174. The IRS intends to propose regulations consistent with the guidance that would apply for taxable years ending after Sept. Taxpayers cannot rely only on certain sections while taking differing positions on other sections in the notice. Taxpayers are not yet required to implement the guidance provided in the notice, but can rely on the interim guidance if they implement all the rules. Cost sharing arrangements under Section 482.The interaction of Section 174 with long-term contracts under Section 460.The identification and allocation of SRE expenditures.The treatment of research performed under contract.The much-anticipated interim guidance, which taxpayers have the option of relying on immediately, addresses several issues, including: ![]() The release provides the first substantive guidance for complying with the new rules after the IRS initially focused on procedural guidance for implementation. The IRS has released interim guidance ( Notice 2023-63) to clarify the treatment of specified research and experimental expenditures (SRE) under Section 174, which must be capitalized and amortized under the Tax Cuts and Jobs Act (TCJA). ![]()
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