Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section 174

By: Adam S. Halpern , Michael Knobler , Larissa B. Neumann , William R. Skinner , Julia Ushakova-Stein , Ariel Love , Sean P. McElroy

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on important provisions relevant to include for companies in the technology, life sciences and other industries engaged in significant research and development. Key topics included: the treatment of contract R&D arrangements, Section 280C’s adjustments for the research credit, and dispositions of intangibles with capitalized R&D under Section 174(d). 

For a copy of the comment letter, please click here.


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