32) Where equipment is removed from a building or structure," some agents have cited section 280B to require the costs of removal to be capitalized
30,225,000 class D fourth priority floating rate capitalized
interest term notes due 2037 'A';
Thus, costs incurred in issuing debt to finance an asset or stock purchase are debt issuance costs and are not capitalized
into the basis of the acquired assets.
This section says that if a taxpayer acquires property subject to a lease, none of the purchase price may be allocated to the leasehold interest; instead, the entire amount must be capitalized
The IRS ruled first that legal fees incurred for services performed in drafting a merger agreement must clearly be capitalized
as incident to a reorganization, since the merger changes the capital structure of the corporation.
13,350,000 class D fifth priority floating rate capitalized
interest term notes 'A';
263(a)-5(c)(8), amounts paid to terminate an applicable transaction to engage to another such transaction must be capitalized
if the transactions are mutually exclusive.
Because the origin was the acquisition of an asset, the expenditures should have been capitalized
for tax purposes and not deducted.
11) The primary criteria for distinguishing whether a cost will be deductible under section 162 or capitalized
under section 263 is whether the expenditure adds value, substantially prolongs the useful life of taxpayer property, or adapts property to a new use.
and operational, conduct the spin off with each SBU trading as an independent company.
The following items may appear to create a separate and distinct intangible, but need not be capitalized
, under Regs.
However, if the taxpayer negotiates a new lease for property covered by an old lease, the cancellation payment should be capitalized
and amortized over the life of the new lease.
2) Although the IRS repeatedly asserts that Indopco "does not change the fundamental legal principles for determining [if the expenditure] must be capitalized
,"(3) the Court's decision has sparked a renewed focus on capitalization issues.
There is a family of pension-capitalized
investment funds with over $8 billion in assets doing business in Pennsylvania or nearby states, making good returns and yielding good jobs in advanced manufacturing, renewable energy and alternative transportation, housing and commercial construction," said Gerard, who has led efforts to launch new funds capitalized
by workers' assets in the U.
The proposed regulations offer substantial guidance on certain costs related to the acquisition, creation or enhancement of intangible assets and certain transaction costs; they also provide numerous definitions, examples, concessions and rules of administrative convenience, aimed at reducing the level of disagreement between taxpayers and the IRS over whether these costs should be capitalized