Under this approach, there are two different techniques for converting net operating income into a value indication: 1) direct
capitalization, which employs an overall
capitalization rate on the net operating income from a stabilized 12-month period and 2) yield
capitalization, which employs an internal rate of return on a stream of annual cash flows and a residual
capitalization rate on the reversionary property value at the end of the projected investor holding period.
Rather, they are intended to strike an appropriate balance between the Code's
capitalization provisions and taxpayers' ability to comply, and the IRS's abilivy to administer the law.
The current
capitalization rate spread reflects what we're seeing happen with Class A properties and what they're trading at," said Sweeney.
Capitalization also may be required where the costs give rise to a significant future benefit.
As of September 30, 2000, The Morgan Stanley Capital International (MSCI) Emerging Markets Free Index
capitalization of $1.
Thus, requiring
capitalization would be an overly broad application of Lincoln Savings and INDOPCO.
Indeed, the National Taxpayer Advocate identified
capitalization issues as the most litigated issue for business taxpayers in the 1998 Report to Congress, and there is no sign the controversy has abated.
Since 1991, REIT industry market
capitalization has grown from nearly $13 billion to more than $80 billion.
The IRS position on the issue of expense versus
capitalization of environmental assessment and cleanup costs is documented in TAM 9315004, issued in April 1993.
The ANPRM addresses specific types of expenditures for which
capitalization is expected to be required, and specifically provides that "[t]he IRS and Treasury Department anticipate that other expenditures to acquire, create, or enhance intangible assets or benefits generally will not be subject to
capitalization under section 263(a).
