Comment from OpenAI

OpenAISupportBusiness
Summary: OpenAI is requesting that the IRS and Treasury modernize Treas. Reg. Section 1.41-2(b)(4) to eliminate or clarify the "primary user" requirement for computer-use costs in qualified research. They argue the current regulation is outdated for modern AI research, which relies on third-party compute infrastructure, and that the current rule creates unnecessary uncertainty for taxpayers.
See attached file(s)

View on Regulations.gov