For income-producing properties, the income
capitalization approach is considered to be the most reliable and relevant appraisal method.
263(a)4(b)(1)(iii), tire types of costs requiring
capitalization include amounts paid to "create or enhance a separate and distinct intangible asset," as defined by Regs.
The highest
capitalization rate for the sector during the fourth quarter was 13.
8) In public remarks, senior IRS and Treasury officials downplayed this perception, suggesting the increase in
capitalization issues was due in part to the changing nature of the American economy and the emergence of an increasing array of intangibles that had never before been scrutinized under section 263.
The largest 100 companies in the index represent roughly 66 percent of its
capitalization, and the top ten represent nearly 23 percent.
This rating reflects Pacific Guardian's balanced operating profile, consistent statutory earnings, solid balance sheet and sound
capitalization.
Recently, a group of companies and their advisers--the INDOPCO Coalition submitted a proposal to the Treasury Department and IRS outlining an approach to future
capitalization guidance.
The IRS noted that
capitalization of such costs is deemed appropriate when there is a documented remediation plan, since having such a plan in place suggests the activities undertaken are more than incidental repairs.
Cotner also manages the Kemper Small
Capitalization Equity Fund (KSCF), a front-end load mutual fund.
In the meantime, the intensifying competition from the regional reinsurers, whose
capitalization has also been increased in recent years, shall continue to pose challenges to Central Re going forward.
Thus, almost 10 years after INDOPCO, the ANPRM was issued to clarify the long-term future-benefit test by outlining the framework for
capitalization issues that the IRS and Treasury expect to provide.
Specifically, we believe that examinations of both
capitalization issues and qualifying research activities for the research tax credit consume disproportionate amounts of taxpayer and government resources.
