Taxpayers must capitalize
the costs of creating, originating, entering into, renewing, or renegotiating five specific types of financial interests: (i) ownership interests in certain entities (e.
If this happens taxpayers either should negotiate a reimbursement from the seller or be prepared to capitalize
This brings us to NAFTA's second overlooked benefit: it accepts and capitalizes
on the global economy's evolution.
One outstanding issue for taxpayers is whether a buyer should deduct or capitalize
amounts it later pays on a liability in excess of the original amount capitalized.
96-62,(4) and revenue agents have not interpreted the advertising ruling as giving them a green light to capitalize
Developers might no real not realize that, under these proposed rules, they could be required to capitalize
land very early in the development process.
What is the most difficult aspect of structuring the best way for a client to capitalize
on nanotechnology and IP?
The IRS requires businesses to capitalize
reengineering costs (see TAM 9544001 on reengineering in a conversion to just-in-time manufacturing).
Since revenue agents persist in joining two amorphous judicial doctrines -- the more than incidental future benefit' test of capitalization under INDOPCO and the "plan of rehabilitation" doctrine -- to meld independent repair projects together and thereby capitalize
removal costs to the replacement assets, we believe that the National Office should issue guidance confirming that removal costs relate to the disposition of the replaced asset and hence remain deductible.
Therefore, a taxpayer that acquires an asset to get out from under a burdensome lease will be required to capitalize
the entire payment regardless of the underlying value of the purchased property.
Commissioner,(6) the Third Circuit, in affirming a Tax Court decision, held that a corporation must capitalize
consulting fees, legal fees, and other expenses incurred in deciding whether to accept a friendly takeover bid.
The regulations generally require a taxpayer to capitalize
costs incurred in the process of "investigating or otherwise pursuing" one of several types of enumerated transactions.