Olson's work at the Treasury Department on tax shelters, capitalization issues
, and simplification, as well as her continuing outreach to TEI and other tax organizations.
All 20 largest capitalization issues
, except for Hanvit Bank rose.
Observation: Revenue procedure 98-17 signals that it is the IRS's intention to continue addressing capitalization issues
one by one, taxpayer by taxpayer.
Three years ago, the IRS's Large and Mid Size Business Division (LMSB) was spending 25 percent of its time on capitalization issues
8) In public remarks, senior IRS and Treasury officials downplayed this perception, suggesting the increase in capitalization issues
was due in part to the changing nature of the American economy and the emergence of an increasing array of intangibles that had never before been scrutinized under section 263.
The ANPRM's purpose is to reduce disputes on capitalization issues
related to intangible assets.
Olson said that additional guidance on capitalization issues
would likely be issued, but the resources are not currently available for such a project.
In an advance notice of proposed rulemaking (REG-125638-01), the IRS announced its intention to issue regulations that will address capitalization issues
involving the significant-future-benefit test (see "Proposed Guidance on Capitalization" below).