What does Notice 2023-63, Guidance on the New R&D Amortization and Capitalization Requirements, Mean for Taxpayers?
On September 8, 2023, the Internal Revenue Service (“IRS”) and Department of the Treasury (“Treasury”) released an advance version of Notice 2023-63. This Notice provides interim guidance intended to clarify the amortization and capitalization of specified research and experimental (“SRE”) expenditures under Section 174, amended by the Tax Cuts and Jobs Act (TCJA) in 2017. Proposed regulations provide rules consistent with the guidance for tax years ending after September 8, 2023. Until those regulations are provided, tax professionals can rely on interim guidance....