Revenue Procedure 2007-53 section 4.05 states that if a taxpayer receives a payment that is partly trade discount and partly cooperative advertising, the taxpayer may use the Advance Trade Discount Method "only with respect to the portion of the payment that is allocable
to the advance trade discount based on objective criteria" There is no mention of whether the obligation to repay is crucial in carving out part of the advance as cooperative advertising.
The Temporary Regulations provide the general rule that a taxpayer may determine the amount of W-2 wages "properly allocable
" to DPGR by using any "reasonable method that is satisfactory to the Secretary based on all the facts and circumstances." (14) In apparent recognition that such language offers taxpayers a great deal of flexibility, but not much certainty, the Temporary Regulations also provide safe harbor methods.
interest deductions are computed on an avoided-cost method that uses the avoided-cost rules of Sec.
The crux of the issue is whether environmental cleanup costs are properly allocable
After allocating the basis and the amount realized between these portions, Bob determines that $12,000 of the gain is allocable
to the residential portion and $6,000 is allocable
to the rental portion.
to common stockholders for the year ended December 31, 2013 was USD1.1m, or USD0.13 per diluted common share, compared to a loss of USD693,000, or USD0.38 per diluted common share, for the year ended December 31, 2012.
QPAI is domestic production gross receipts (DPGR) less allocable
cost of goods sold (COGS), if any, less allocable
expenses, losses, or deductions.
(2) expenses directly allocable
to the receipts, and
However, section 163 (h)(1) bars individuals from deducting "personal interest." Section 163(h)(2)(A) defines this term as any interest allowable as a deduction, other than that paid or accrued on debt "properly allocable
to a trade or business" (other than the trade or business of being an employee).
Memo 1991-557, 11/7/91), the Tax Court held Black & Decker's worthless stock loss in a foreign subsidiary, claimed in a pre-TRA 86 taxable year, to be allocable
entirely against its foreign source income for purposes of determining its foreign tax credit limitation.
Operator of healthcare services firms First Physicians Capital Group Inc (FPCG) (OTCBB:FPCG) on Friday reported preliminary un-audited net loss allocable
to common stockholders of USD10.4m for its fiscal year ended 30 September 2010.
1.263(a)-5(f) provides detailed rules on the supporting records required from the taxpayer to establish the extent to which costs relating to a covered transaction are allocable
to activities that do not facilitate the transaction and are thus potentially deductible.