R&D 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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