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Jim Gadwood Quoted in Tax Notes Regarding Anticipated Guidance on Research Expenditures

"Clock is Ticking on Research Amortization Help"

Tax Notes

Jim Gadwood discussed guidance he expects to see by the end of 2022 relating to amortization of research and experimental expenditures under section 174. He anticipates both substantive proposed regulations and a revenue procedure addressing related accounting method changes. Regarding the proposed regulations, Gadwood said that identifying the line between section 174 and section 162 is one of the key definitional areas to address. "Will we see bright-line rules, or will we see a facts and circumstances approach?" Gadwood asked. He is also looking for guidance on how new section 174 will interact with the uniform capitalization rules in section 263A. Regarding the revenue procedure, Gadwood anticipates the IRS will address whether taxpayers (or at least a subset of them) can forgo filing a Form 3115 to make the accounting method change that occurs upon transitioning to new section 174.