On October 2, 2024, TEI submitted supplemental comments on Notice 2023-63 and section 174, with a particular focus on rules related to software development for future proposed regulations. The comments address timing issues with respect to wage SREs, the appropriate nexus for indirect costs to be considered SREs, and a reasonable analytical framework under section 174. TEI also provided additional examples that would clarify which software-related costs need to be capitalized under section 174. The letter was a joint effort between the IRS Administrative Affairs Committee, whose chair is Brian Kaufman, and the Federal Tax Committee, whose chair is Betty Mak.
Committee