The study reallocated 10 percent of the construction cost to 15-year site improvements and 20 percent to five- and seven-year
tangible personal property.
Wisconsin does not define
tangible personal property or computer software within its corporate income tax law.
(4) See Q 1323 for the rules that apply to gifts of
tangible personal property, and Q 1324 regarding gifts to private foundations.
After an analysis of the relevant financial metrics, the client sliced 45 percent off of the value of its
tangible personal property, leading to a tax savings of $260,000.
CPAs may want to read Senate report 1881, which accompanied the Revenue Act of 1962, and Senate report 95-1263, which accompanied the Revenue Act of 1978, which both amplify and elucidate the distinction between
tangible personal property and structural components.
The exception lies for "Machinery, or equipment for use or consumption directly and predominantly in the production of
tangible personal property ..." In the case of Burger King, the company sustained their burden, arguing that the grills they provided to franchisees produced "
tangible personal property," i.e.
COURT'S OPINION: The Court of Appeals of Texas reversed the judgment of the lower court and held that the patient failed to demonstrate a "waiver of immunity" based on the alleged misuse of
tangible personal property, to wit, the hospital bed.
When dealing with depreciation and buildings, there are two types of property: tangible real property and
tangible personal property. Tangible real property is depreciated over 39 years, or 2.56 percent each year.
For gifts of
tangible personal property, the change is retroactive to July 1, 1992.
The purchased
tangible personal property must be one of the following items:
9/11/15), the Supreme Court held that a taxpayer's sales of services should be sourced using a transactional rather than an operational approach under the COP method for sourcing sales other than sales of
tangible personal property. In affirming the Oregon Tax Court, the Supreme Court held that the definition of "income-producing activity" as it applies to a COP analysis relates to individual sales to customers.
In April, the 3rd Court of Appeals sided with the parent company of AMC movie theaters and issued a ruling widening the definition of "
tangible personal property" under the state's tax code, allowing the chain to lower its tax burden.