12) In response, some taxpayers suggested adopting the "functional interdependence test" applied for purposes of section 263A(f) in determining whether and how much interest to capitalize
in connection with a capital improvement project.
The simple answer is because there is no earthly reason to capitalize
any of these words.
This has become is a must for us, so that come game time our offensive personnel will recognize and capitalize
on anything the defense gives us.
A direct reading of the opinion leads to the simple conclusion that companies must capitalize
liabilities assumed in asset acquisitions.
263(a)-4(c) requires taxpayers to capitalize
costs incurred in connection with the acquisition of a laundry list of intangibles, including, for example, an ownership interest in a corporation, partnership, or LLC; a variety of financial interests and products; insurance and annuity contracts; leases; patents and copyrights; as well as both "customer-based" and "supplier-based" intangibles.
Under Webb an acquirer generally must capitalize
the payment of a prior owner's liabilities.
In Russia, Eastern Europe and many nations where economic evolution is dramatic and difficult today, people make a leap of faith in the global market's capacity to create opportunity and their ability to capitalize
But in another case where the death occurred before the acquisition, the buyer had to capitalize
rather than deduct the payments (David R.
Otherwise, they would strain to capitalize
all sorts of expenses that historically have been currently deducted.
The proposed rules, if finalized in current form, could require developers to capitalize
the interest expense of property to be developed even before they begin construction of residential units.
If you were doing due diligence on a new client, in terms of judging their best course of action and any the best way to help capitalize
on interests in nanotechnological intellectual property, what would you look at with respect to their company, competitors, industry or anything else?
The IRS normally takes the position that businesses must capitalize
the cost of enterprise-resource-planning software (ERP) and amortize it over 36 months.
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.