Rather, losses realized on a position of an identified straddle are capitalized
into the basis of each identified offsetting position.
In Revenue Ruling 94-38, the IRS accepted the holding of Plainfield-Union that the appropriate test for determining whether an expenditure increases the value of property (and thus must be capitalized
under section 263) is to compare the status of the asset after the expenditure with the status of the asset before the condition arose that necessitated the expenditure.
If this threshold is exceeded, all costs must be capitalized
. Although the exception is a departure from prior law, it may have only limited usefulness for most corporate taxpayers.
Therefore, the court treated the payment as a modification fee to be capitalized
and amortized over the life of the new lease.
* If some or all of the expenditures are likely to be capitalized
, prepare an analysis of the expected useful life or otherwise establish the wasting aspects of the benefits to prevent the creation of a nonamortizable asset.
The TAM concludes that expenditures for removing asbestos from the boiler house must be capitalized
for two reasons.
While Treasury's published position was that INDOPCO did not change the fundamental principles for determining whether a particular expenditure may be deducted or has to be capitalized
, many types of business expenditures became subject to greater IlLS scrutiny on the basis of the future benefit standard articulated in the INDOPCO decision.
Another questionable practice that will be curtailed involves what can be capitalized
and amortized as overhead.
The capitalization statistics for Q 12013 were as follows: 97.3% of the banks were Well Capitalized
, another 1.3% were Adequately Capitalized
, and less than 1.5% of the banks were either Under Capitalized
, Severely Under Capitalized
, or Critically Under Capitalized
471 cost in an amount that is greater than the amount required to be capitalized
for tax purposes.
Honohan said, 'Irish banks are going to leave this situation well capitalized
with a solid framework ...