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Taxpayers must capitalize the costs of creating, originating, entering into, renewing, or renegotiating five specific types of financial interests: (i) ownership interests in certain entities (e.
This brings us to NAFTA's second overlooked benefit: it accepts and capitalizes on the global economy's evolution.
One outstanding issue for taxpayers is whether a buyer should deduct or capitalize amounts it later pays on a liability in excess of the original amount capitalized.
The IRS requires businesses to capitalize reengineering costs (see TAM 9544001 on reengineering in a conversion to just-in-time manufacturing).
Such guidance will afford taxpayers much greater certainty than the nebulous more than incidental future benefit" test set forth in INDOPCO -- a test that can all-too-easily be misapplied to capitalize routine, on-going, or recurring expenditures.
As most taxpayers probably do not capitalize these internal costs, the regulations will not change the current practice.
The government wanted it to capitalize the entire purchase price.
Commissioner,(6) the Third Circuit, in affirming a Tax Court decision, held that a corporation must capitalize consulting fees, legal fees, and other expenses incurred in deciding whether to accept a friendly takeover bid.
The regulations generally require a taxpayer to capitalize costs incurred in the process of "investigating or otherwise pursuing" one of several types of enumerated transactions.
One of the most difficult questions a company faces is whether it must capitalize an expenditure or whether it can deduct it.
42) Finally, "although taxpayers generally must capitalize the costs of acquiring intangible assets from another person (such as the cost of acquiring a customer list or goodwill), taxpayers generally may deduct the costs incurred to develop or maintain such intangible assets.
Early on, Seydoux foresaw the central role the cellphone - and now the smartphone -- would play in consumers' everyday lives, and began developing the technology and a product roadmap to capitalize on the mobile phone phenomena.