263(a)-5 regarding the tax treatment of transaction costs capitalized
in connection with tax-free acquisitive transactions, as well as costs capitalized
by a target in connection with taxable stock acquisitions.
23,750,000 class J eleventh priority floating rate capitalized
interest term notes 'BB';
during 1991 relate to products introduced in 1991 or that will be introduced during 1992.
24,937,500 class G floating rate capitalized
interest notes due 2042 'BBB+';
Costs deemed to be inherently facilitative to a transaction are required to be capitalized
, regardless of when incurred in the corporate acquisition timeline.
However, if the payment would have to have been capitalized
or if the acquisition was a stock sale, a capital loss should be the result under the Arrowsmith doctrine.
In other words, examining agents will adopt a broad definition of the "new business," claim that a taxpayer's training expenses relate to such "new businesses," and thereby rule that the expenses must be capitalized
Simon's risk-adjusted capital ratio has improved materially over the past 3 years that further illustrates that the company is appropriately capitalized
for the 'A' rating category.
As described above, losses realized on one leg of an identified straddle are capitalized
into the basis of the offsetting leg, rather than suspended under the general loss deferral rule.
The cost of property with a useful life in excess of one year generally must be capitalized
under section 263.
7% of Georgia banks were Well Capitalized
and another 6.
752-2(j) anti-abuse rule could be expanded to cover certain situations involving thinly capitalized
The proposed "tangibles regulations" published in the Federal Register on August 21, 2006 (1) largely refine and clarify rather than fundamentally change the decades-old criteria for distinguishing between deductible expenses incurred to repair and maintain tangible property and capitalized
costs incurred to acquire, produce, or improve such property.
However, a look at equipment operating lease statistics only shows that the vast majority of the transaction volume is comprised of small and mid-sized transactions of less than $250,000, with average lease terms of less than four years, whose capitalized
value would be less than 0.
Selden) didn't have her 'A' game today, and Georgia capitalized
on the few slips and put us in a situation we were going to have to climb out of.