IRS Notice: Amortization of Specified Research or Experimental Expenditures Guidance (IRC §174)

The IRS intends to issue proposed regulations addressing: (1) the capitalization and amortization of specified research or experimental (SRE) expenditures under I.R.C. §174, as amended by TCJA of 2017, Pub. L. No. 115-97 (Dec. 22, 2017); (2) the treatment of SRE expenditures under §460; and (3) the application of §482 to cost sharing arrangements involving SRE expenditures, the IRS announced. The forthcoming proposed regulations will be consistent with the interim guidance provided in sections 3 through 9 of this notice. Section 10 of the notice provides that taxpayers may rely on the interim guidance provided in sections 3 through 9 ...