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Episode 84: US § 174 – getting your arms around the new R&D capitalization rules

May 13, 2022


In this TP Talks episode, Erin March (Transfer Pricing Principal, PwC US), Dennis Tingey (Tax Services Partner, PwC US), and Marco Fiaccadori (Transfer Pricing Principal, PwC US National Tax Services) discuss the R&D capitalization requirements under the new US § 174 regulations, focusing on transfer pricing-related questions and issues, including the definition of amortization under Section 174, primary issues taxpayers are dealing with post-Q1, impact on key U.S. international tax provisions, contract R&D/R&E arrangements, and the interplay of Section 174 capitalization and the cost sharing rules under Section 1.482-7.

Contacts: Erin March, Dennis Tingey, Marco Fiaccadori

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Horacio Peña

Horacio Peña

Global Transfer Pricing Leader, PwC United States

Tel: +1 (917) 478-5817