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Because nothing can be published in either the Federal Register or the Internal Revenue Bulletin without the concurrence of the Assistant Treasury Secretary (Tax Policy), the Commissioner, and the IRS Chief Counsel, no cost can now be capitalized under the significant future benefit standard unless (i) it is specifically identified in the final regulations as a capital expenditure, or (ii) the Assistant Secretary, the Commissioner, and the Chief Counsel all agree that the purported future benefit is in fact significant enough to require capitalization.
21,250,000 class H tenth priority floating rate capitalized interest term notes 'BBB-';
This change during the fourth quarter had no effect on earnings reported for 1991 and no effect on the amount of capitalized Research and Development Costs for 1991.
21,612,500 class F floating rate capitalized interest notes due 2042 'A-';
263(a)-5(a) provides that costs incurred after a formal decision is made to pursue a transaction are facilitative and must be capitalized.
In GCM 39274 the IRS did caution that had the company terminated the plan immediately, it could have capitalized the expenses, as in Webb.
The Journal story exaggerates the significance of what it calls a "precedent-setting" 1995 technical advice memorandum (PLR 9544001), in which the IRS held that certain just-in-time manufacturing expenses (including training costs) must be capitalized.
Fitch calculates Simon's interest coverage (as defined by recurring EBITDA divided by the sum of interest expense and capitalized interest) to be 2.
Rather, losses realized on a position of an identified straddle are capitalized into the basis of each identified offsetting position.
First, in revenue ruling 96-62 (1996-2 CB 9) the IRS said the Indopco decision (503 US 79) would not cause training costs to be capitalized.
8) Since the expenditures do not improve the software beyond the state in which it was intended to be used and do no more than restore it to its normal operating state, the EITF concluded that such costs -- being indistinguishable from other forms of repair and maintenance expenses -- are "period costs and should be expensed as incurred' rather than capitalized.
6% of the banks were either Under Capitalized, Severely Under Capitalized, or Critically Under Capitalized.