The IRS released an advance version of Notice 2023-63 providing interim guidance intended to clarify the application of section 174, as amended by the “Tax Cuts and Jobs Act” (TCJA).

The notice includes guidance addressing capitalization and amortization of specified research or experimental (SRE) expenditures under section 174, as amended. Based on our review and consultantion with industry experts, here is a quick summary of the the expenses tax return preparers (CPAs or EAs) have to capitalized in calculating the 2023 and possibily 2024 taxable income for entities.

The IRS notice you provided (Rev. Proc. 2023-8) specifies the types of expenses or categories that need to be capitalized under §174 of the Internal Revenue Code, particularly as modified by the Tax Cuts and Jobs Act (TCJA). These expenses must be capitalized and amortized over a 5-year period (or a 15-year period if the research is conducted abroad). This applies to expenses incurred in taxable years beginning after December 31, 2021. The following are examples of expenses that need to be capitalized and amortized over a 5-year or a 15-year period:

Specified Research or Experimental Expenditures:

Salaries and Wages: Expenses related to compensation for employees directly involved in research activities
Supplies and Materials: Costs of materials and supplies used directly in R&D activities:
Payments to Contractors: This includes outsourced research services or expert consulting fees:
Rented Equipment: Any rental or leasing costs for equipment used exclusively in research and experimentation:
Utilities and Overhead Expenses: These are indirect costs that can be allocated to R&D activities:
Software Development Costs: Software-related expenses tied to the creation of new software or programs:
Clinical Trials (for industries like pharmaceuticals or biotechnology): Specific costs related to testing and developing new products, particularly in life sciences:

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