capitalization issue to permit taxpayers to file accounting method changes under recently issued temporary regulations and revenue procedures.
Although most considerations of the
capitalization issue focus on the "asset," an attempt to clearly reflect income should actually guide the ultimate determination.
WITH RESPECT TO THE
capitalization issue, the IRS argues that the Tax Court erroneously concluded that Eastland was adequately capitalized because its capitalization complied with Bermuda regulatory laws.
The AICPA has the advertising cost
capitalization issue, an issue of soft-cost recognition.
Taylor does not address the
capitalization issue. The high market capitalization rates for Japanese city banks have given them the financial strength to make inroads into foreign markets.
2002-9 provides a sensible resolution to the
capitalization issue: impact fees incurred in connection with the construction of a new residential rental building are capitalized costs allocable to the building and, thus, depreciable.
This
capitalization issue will likely be raised in many IRS examinations until the matter is resolved in the courts.
All taxpayers are eligible for this relief, even if an IRS examination is in progress, with one basic exception: audit protection is not available with respect to any interest
capitalization issue "under consideration" by the Service in an examination on Mar.
bank there is no thin
capitalization issue under present law, even if the debt is backed by a parent's guarantee.
He is currently an independent consultant, advising media and technology clients on strategy, business model and
capitalization issues. Most recently, he served as senior vice president of strategic planning and corporate development for Dolby Laboratories, Inc., where he was responsible for corporate development, mergers and acquisitions, investments, and corporate strategy.
Some banks are also dealing with
capitalization issues. Meanwhile, lack of clarity regarding government spending plans, including potential cuts, is not helping sentiment.