Three years ago, the IRS's Large and Mid Size Business Division (LMSB) was spending 25 percent of its time on capitalization issues
Observation: Revenue procedure 98-17 signals that it is the IRS's intention to continue addressing capitalization issues
one by one, taxpayer by taxpayer.
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.
Olson said that additional guidance on capitalization issues
would likely be issued, but the resources are not currently available for such a project.
The ANPRM's purpose is to reduce disputes on capitalization issues
related to intangible assets.
Brokers said short-term funds are increasingly flowing out of large capitalization issues
to medium and small caps on the Tokyo market mainly because investors are concerned about the downside risks of international blue chips along with a slump in their U.
Approximately 25 percent of the IRS's time is spent on capitalization issues
In an advance notice of proposed rulemaking (REG-125638-01), the IRS announced its intention to issue regulations that will address capitalization issues
involving the significant-future-benefit test (see "Proposed Guidance on Capitalization" below).
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.