Episode 84: US § 174 – getting your arms around the new R&D capitalization rules
May 13, 2022
Overview
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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Contact us
Kristina Novak
Washington National Tax Services, Transfer Pricing, Principal, PwC US
Tel: +1 (469) 878-4552
John Cianfrone
Washington National Tax Services, Transfer Pricing, Director, PwC US
Tel: +1 (646) 951-7680