For large corporations, capitalization issues
comprise the primary source of contested tax determinations.(5) Even though the Danaher ruling cannot provide reliable precedent for other taxpayers,(6) it suggests that many other businesses face the risk of unanticipated adjustments related to their training expenditures.(7) This threat appears realistic in light of recent claims of increasingly aggressive IRS behavior in capitalization issues
,(8) despite a denial by the Service of any change in its policy.(9) Regardless of any change in position, the ruling adds uncertainty to the treatment of training expenditures at a time when manufacturers implement new processes and procedures almost daily.(10)
95-19 indicates that an interest capitalization issue
is under consideration if the taxpayer has received written notification, including an information document request, identifying a method or submethod as under consideration.
The IRS continues to provide guidance for certain industries through its Industry Issue Resolution program, addressing capitalization issues
and challenges unique to certain industries.
BNY Mellon's fiscal stability throughout the financial crisis, our understanding of the current environment and our ability to provide the right tools to respond to the ongoing market challenges, have made our bank an attractive source of investment advice at a time when many financial institutions are themselves grappling with liquidity and capitalization issues
Timing and capitalization issues
have been raised with regard to certain trade channel promotion expenditures.
WAM is best described as a relative value manager emphasizing mid-to-large capitalization issues
with both value and GARP (Growth At a Reasonable Price) overlays.
In simplistic terms and ignoring the capitalization issues
, a property that a building owner might realistically value at $1 million would be assessed at $450,000 by the city using its targeted 45 percent ratio, but assessed at $350,000 if using a generic 35 percent SBEA figure.
At the other extreme, the third segment of Qualivest Equity Fund consists exclusively of small capitalization issues
managed by a third specialist.
It is particularly timely, given ongoing developments on capitalization issues
. (For a full discussion of the district court's decision, see Shin, Tax Clinic, "Deduct or Capitalize Aircraft Engine Maintenance Costs?," TTA, February 2004, p.
Olson's work at the Treasury Department on tax shelters, capitalization issues
, and simplification, as well as her continuing outreach to TEI and other tax organizations.
The committee said that "in general, the proposed regulations substantially simplify and resolve the numerous capitalization issues
generated by the [U.S.] Supreme Court's decision in Indopco, Inc.
All 20 largest capitalization issues
, except for Hanvit Bank rose.
Although various IlLS rulings issued subsequent to INDOPCO sought to clarify that decision's scope, the IRS recognized, with the publication of Notice 96-7 (inviting the public to suggest standards for broader guidance on capitalization issues
), that its piecenieal approach to issuing specific guidance was unlikely to reduce the controversy.
Three years ago, the IRS's Large and Mid Size Business Division (LMSB) was spending 25 percent of its time on capitalization issues