George Hani commented on the guidance the Internal Revenue Service (IRS) provided on December 12 regarding accounting method changes required to come into compliance with the new requirement to amortize Research & Development (R&D) expenditures under Section 174.  While Section 174 expenses were previously currently deductible, the 2017 Tax Cuts and Jobs Act (TCJA) required these expenditures to be amortized over a period of five years starting in January 2022. Changing from a current deduction to five-year amortization constitutes a change in method of accounting that requires the consent of the Commissioner. In the guidance, the IRS indicated the method change prompted by the TCJA amendment to Section 174 would be an "automatic" method change, which taxpayers do not need to address until they file their return for the tax year, as opposed to a "non-automatic" change which requires taxpayers to do something before the end of 2022. "If the IRS did not release this guidance on Section 174 of the tax code," Hani noted, "taxpayers would have needed to go through a procedure that would indicate a non-automatic change by the end of 2022."