Taxpayers using either the section 861 method (16) or the simplified deduction method (17) to allocate costs may use the "Wage Expense Safe Harbor" to determine the amount of W-2 wages properly allocable
Note that the final regulations do not appear to permit attribution of activities for purposes of determining the allocable
portion of W-2 wages outside the consolidated return context.
The following table reconciles net income allocable
to common stockholders to funds from operations allocable
to common stockholders (unaudited, amounts in thousands, except per share amounts):
A foreign partner's allocable
share of partnership ECTI for the partnership's tax year is equal to that foreign partner's distributive share of partnership gross income and gain effectively connected and properly allocable
to the partner under Sec.
3) a ratable portion of other deductions not directly allocable
to DPGR or to another class of income.
If a lease is subject to those rules, the IRS may ignore its express terms and redetermine the amounts of income allocable
to the landlord and rent deductible by the tenant (based on the present value of future lease payments).
172 is the difference between the (1) NOL for the tax year and (2) NOL for the tax year without including deductions for interest on the portion of any debt allocable
to a CERT (i.
Although aimed principally at manufacturers, the new deduction will benefit a relatively wide range of businesses and may well generate years of controversy regarding the meaning of "production" activities as well as the items of revenue and expense allocable
to such activities.
3 million, Novo reported a net loss allocable
to common shareholders of $2.
participant can claim a credit for its allocable
share of foreign taxes on its U.
Net income allocable
to common shareholders for the three months ended June 30, 2009 was $8.
Whenever a vacation property qualities as a rental with personal usage (because personal use was not greater than 14 days or 10%), the portion of the mortgage interest allocable
to the owner's usage is no longer deductible; the property does not qualify as a personal residence.