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.
Stocks traded on ``bulletin boards'' and ``pink sheets'' tend to be highly speculative, extremely small capitalization issues
that trade for as little as a few cents a share, usually for good reason.
Earlier in the financial crisis, lenders were slow to conclude loan sales, given bank capitalization issues
and to accept losses based on heavily discounted purchase offers.
Three years ago, the IRS's Large and Mid Size Business Division (LMSB) was spending 25 percent of its time on capitalization issues
There are also risks associated with small and mid-capitalization issues
such as market illiquidity and greater market volatility than larger 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.
and will support Theisen in a variety of activities including acquisition work, strategic direction, board relations, governance, and capitalization issues
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).