Research and Development: Notice 2023-63 Overview

In September 2023, the IRS published Notice 2023-63, announcing that the Treasury and IRS intend to issue proposed regulations clarifying the capitalization and amortization of specified research or experimental (SRE) expenditures under IRC 174.

Bloomberg Tax’s Research & Development Notice 2023-63 Overview is a comprehensive roadmap that will help tax professionals get clarity on how these SRE expenditures are treated for purposes of IRC 174, including the discussion of:

• Scope of IRC 174
• Whether certain activities constitute software development
• Clarity regarding research performed under contract for purposes of IRC 174
• Application of IRC 482 to cost sharing arrangements involving SRE expenditures

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