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September 21, 2023

Tuesday, October 3 | IRC Section 174 interim Treasury and IRS guidance: Technical aspects, business implications and uncertainties of Notice 2023-63 (1 pm ET)

The IRS has issued highly anticipated interim guidance (Notice 2023-63) on the amortization of specified research or experimental (SRE) expenditures under Section 174. In the notice, issued September 8, 2023, the IRS also announced its intent to issue proposed regulations consistent with the guidance in the notice. These forthcoming proposed regulations would apply to tax years ended after September 8, 2023. Taxpayers, however, may, with limited exception, rely on the rules in the interim guidance retroactively to tax years beginning after December 31, 2021.

Join our team of Ernst & Young LLP subject matter professionals for a discussion of the technical aspects, potential implications and uncertainties of the notice. On the webcast, we will address:

  • Identifying, allocating, and amortizing SRE expenditures
  • Determining whether certain activities constitute software development
  • Determining whether costs paid or incurred for research performed under a contract are SRE expenditures
  • Treatment of SRE expenditures if the related property is disposed of, retired or abandoned during the amortization period
  • Potential changes to current regulations under Sections 460 (long-term contracts) and 482 (cost-share arrangements)

Date: Tuesday, October 3, 2023

Time: 1:00-2:30 p.m. ET New York; 10:00-11:30 a.m. PT Los Angeles

Registration: View archive here.


Alexa Claybon, Principal, National Tax, Accounting Periods, Methods and Credits, Ernst & Young LLP

Rayth Myers, Senior Manager, National Tax, Accounting Periods, Methods and Credits, Ernst & Young LLP

Michael Bowes, EY Americas Transfer Pricing Advisory Leader and Partner, National Tax, Ernst & Young LLP

Brian Peabody, Principal, National Tax, International Tax and Transaction Services, Ernst & Young LLP


Craig Frabotta, EY Global Research Credit Leader and Principal, National Tax, Accounting Periods, Methods and Credits, Ernst & Young LLP

CPE credit offered: up to 1.8 depending on duration. Recommended field of study: Taxes. Learning objectives: Identify key provisions of Section 174 and key aspects of Notice 2023-63, including the Section 174 amortization period, definition of software development, costs paid or incurred under a contract, etc.; recognize potential changes to current regulations under Sections 460 and 482 and unanswered Section 174 questions following the notice. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

EY webcast managed and produced by Ernst & Young LLP's Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax | and Barbara Kirchheimer |

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