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IRS GuideWire December 22, 2023

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Issue Number:    N-2024-12

Inside This Issue


Notice 2024-12 clarifies and modifies Notice 2023-63 which announced that the Treasury Department and the IRS intend to issue proposed regulations providing rules addressing the capitalization and amortization of specified research or experimental expenditures under § 174. This notice clarifies rules in Notice 2023-63 relating to research performed under a contract. This notice also modifies the reliance rules Notice 2023-63 by removing the requirement that taxpayers must rely on all of the rules in sections 3 through 9 of Notice 2023-63. Finally, this notice clarifies that section 5 of Rev. Proc. 2000-50 (costs of developing computer software) is obsoleted for amounts paid or incurred in taxable years beginning after December 31, 2021.

Notice 2024-12 will be in IRB: 2024-3, dated January 16, 2024

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