Released on September 8, 2023, IRS Notice 2023-63 provides wide-ranging and potentially controversial guidance on the capitalization and amortization of research and experimentation expenses under section 174.The Notice addresses several key questions on capitalization under section 174, which is required for tax years beginning on or after January 1, 2022: When are amounts paid by a service provider in a contract research arrangement subject to capitalization rules? How do the rules apply to R&D costs incurred as part of a...

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Built in 1968, 140 Broadway located in New York City is a stunning Class A vintage office building. Although it has stood in the center of lower Manhattan for more than 50 years, thoughtful planning, a clear vision and collaborative partnership have wiped away the years by proactively repositioning this iconic office building with state-of-the-art amenities. The same thing can be said for One Victory Park and International Plaza in the Dallas area. Tricked out amenity floors using underutilized space...

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Last week, the California Legislature passed two bills, together the "Climate Accountability Package," that would mandate the public disclosure of greenhouse gas emissions (GHG) and climate-related financial risk by companies doing business in California that meet different revenue thresholds. California Governor Gavin Newsom has indicated he will sign the bills into law, subject to "some cleanup on some little language," the details of which remain undisclosed.1California is the first governmental actor in the United States to mandate corporate climate-related...

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On September 15th, Sika announced planned changes to the Board of Directors and the Group Management. The decisions have been made ahead of the presentation of the new growth strategy at the Capital Markets Day on October 3, 2023. Thierry F. J. Vanlancker will be proposed as new Chair of the Board of Directors at the next Annual General Meeting in 2024, as Paul Hälg has decided to step down from his position after twelve successful years to make way for a new...

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On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations addressing the application of Section 174.1 In 2017, legislation commonly referred to as the Tax Cuts and Jobs Act amended Section 174 to eliminate the option for taxpayers to deduct R&E expenditures and instead to require taxpayers to capitalize and amortize “specified research or experimental”...

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Amal Alliance, an international non-profit organization committed to fostering education and well-being among marginalized communities, is thrilled to be part of the prestigious Clinton Global Initiative (CGI) Greenhouse organized for the second consecutive year. As we embark on this journey, Amal Alliance is ready to make an even greater Commitment to Action on pressing issues such as educational change, mental health equity, and creating an inclusive society. Selected from a competitive pool of entrepreneurs and startups, Amal Alliance joins a...

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Key elements of the IRS’s efforts to reverse the sharp decline in audit rates for wealthy individuals, partnerships, and other high-income earners, without increasing audit rates for individuals earning less than $400,000 a year, include the following. Expanding high-income/high-wealth and partnership compliance work Prioritizing high-income cases The IRS’s High Wealth, High Balance Due Taxpayer Field Initiative is intended to intensify work on taxpayers who have more than $1 million in total positive income and $250,000 in recognized tax debt. Building off its...

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On August 23, 2023, the Office of Management and Budget (OMB) published its final guidance implementing the Build America, Buy America (BABA) preference, which requires that all of the iron, steel, manufactured products, and construction materials used in infrastructure projects receiving federal financial assistance be "produced in the United States." Here are the most significant takeaways between the initial April 2022 guidance and final August 2023 guidance: The final guidance provides a new definition of "manufactured products," which provides that...

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