The final regulations require capitalization
of (i) an amount paid to acquire any intangible; (ii) an amount paid to create certain but not all intangibles; (iii) an amount paid to create or enhance a "separate and distinct intangible asset"; and (iv) an amount paid to create or enhance a "future benefit," but only under certain circumstances.
While the rules regarding capitalization
of environmental treatment costs appear consistent with IRS and Financial Accounting Standard Board pronouncements, the TAM's treatment of remediation costs conflicts with the FASB's.
The primary difference between Kemper Small Capitalization
Equity Fund and KIP-Small Capitalization
Equity Portfolio is in the load structure.
In addition, amounts paid to another person to purchase intangible property will be subject to capitalization
Finally, during the liaison meeting, Treasury Department representatives indicated that the government is considering other issues on which to issue broad-based capitalization
guidance, including the plan-of-rehabilitation doctrine and the definition of repairs.
In terms of important indicators - strong, industry-wide performance, growing acceptance of this investment vehicle by Wall Street, particularly pension funds, and industry growth as measured by market capitalization
and increased liquidity - 1996 has shaped up to be a very positive year for REITS," said NAREIT President and CEO Mark Decker.
Under the 1988 IRS notice, it was clear that interest capitalization
was required during construction of buildings and personal property with a class life of 20 years or more.
Marginal growth in surplus, elevated underwriting leverage and significant net catastrophic exposure exacerbated CIRe's risk-based capitalization
in 2005, although the risk-adjusted capitalization
, which is measured by Best's Capital Adequacy Ratio, indicates an adequate margin to support its current rating.
As for the other costs, the IRS concluded that capitalization
might be required, depending on the facts of the case.
Indeed, despite frequent public assurances from the IRS National Office that "INDOPCO did not change the law regarding capitalization
,"(2) agents have seized upon that decision's reference to "future benefits" to support novel capitalization
(large cap) growth stocks are securities which fall into the Russell Top 200[R] Index.
The IRS had previously conceded that the legal expenses attributable to the investigatory stage of the transaction should have been allowed as a deduction, and that the Tax Court was wrong in requiring capitalization
of all of DBTC's legal fees.
1039 (1992), in which the Supreme Court, not surprisingly, required the capitalization
of the costs of a friendly merger that changed the corporate structure and promised long-term synergistic benefits to the taxpayer.
has a market capitalization
of approximately $750 million and gathers, conditions, treats, processes and transports midstream natural gas for a customer base that spans the natural gas and natural gas liquids commodity industries.
Presumably, the financial accounting standard of capitalizing these costs drew the Service's attention, as it provided a convenient argument and numeric support for applying these capitalization
principles for tax purposes.