On July 24, TEI submitted comments on Notice 2023-63 and Section 174, with a particular focus on rules related to software development for future proposed regulations.
TEI requested rules for determining the proper unit of account with respect to specified research or experimental expenditures (SREs) and further guidance on what does and does not constitute software development. TEI included numerous examples that would clarify which software-related costs need to be capitalized under Section 174.
The letter was a joint effort between TEI’s IRS Administrative Affairs Committee, under committee chair Brian Kaufman, and the Federal Tax Committee, under committee chair Betty Mak. Read the comments here.
