Robert Kovacev commented in Tax Notes on the procedural guidance on the new research amortization requirement telling taxpayers how to adopt accounting method changes consistent with the amended law, which doesn't offer much help to taxpayers with controlled foreign corporations (CFCs). Rev. Proc. 2023-11, 2023-3 IRB 417, is the only guidance taxpayers have received so far on the implementation of alterations the Tax Cuts and Jobs Act 2017 (TCJA) made to section 174. The December 2022 guidance tells taxpayers how to change their tax accounting methods to account for the move from expensing research costs to amortizing them. Kovacev pointed to the existing Internal Revenue Service (IRS) audit focus on research to predict an increase in disputes over section 174 amortization. The IRS's strategic operating plan emphasizes centralization and taxpayers should expect to see the effects of that during audits, Kovacev said, noting that could mean more uniform approaches instead of audits tailored to specific taxpayers.