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Entries made on a periodic basis - monthly or quarterly - are suspicious and may relate to period expenses.
To the extent otherwise created, included in this category are records of loans, including third-party loans, relating to transactions between the reporting corporation and a foreign related party; guarantees of debts of the reporting corporation by a foreign related party (or vice versa); hedging and security arrangements between the reporting corporation and a foreign related party; research and development expense allocations; arrangements for furnishing services; patent and copyright registrations; and lawsuits in foreign countries that relate to intercompany transactions.
When a tender offer is "friendly" and a target's costs relate to facilitating the takeover, the costs will constitute a nondeductible capital expenditure.
Even though the costs of the activities of P's engineers relate to the adaptation of a particular customer's need, those activities constitute R&E expenditures for purposes of section 174 because they relate to the development, improvement, or testing of the functional design or specifications of a product.
The investment must not relate to, or be made in the normal course of, the trade or business of the taxpayer or any related person (which includes any contribution or loan to an employee stock ownership plan defined in section 4975(e)(7) or other qualified plan under section 401(a)).
Example: A hospital incurred branch electrical wiring costs consisting of conduit, wiring and electrical connections, which relate to particular items of hospital equipment (such as X-ray film processing equipment and hospital sterilization equipment).