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U.S. IRS Updates Practice Unit on How to Allocate and Apportion Research and Experimental Expenses for Tax Years Beginning Before January 2020

28 February 2024

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Approved Changes

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United States

The U.S. IRS has published an updated practice unit, How to Allocate and Apportion Research and Experimental (R&E) Expenses for Tax Years Beginning Before 1/1/2020. The process overview of the practice unit includes the following: NOTE: Treas. Reg. 1.861-17 regarding the allocation and apportionment of R&E expenditures was significantly revised by TD 9922 in November 2020. The regulations under TD 9922 are for tax years beginning after December 31, 2019. However, taxpayers may choose to apply the new regulations to taxable years beginning on or after January 1, 2018, and before January 1, 2020. This Practice Unit replaces the September...