Prop. Regs. on Sales-Based Royalties and Vendor Allowances
Article:
The IRS issued much-anticipated proposed regulations on the capitalization and allocation of sales-based royalties and on adjustments to the cost of merchandise inventory for sales-based vendor allowances
Published on June 16, 2011
Treatment of Capitalized Costs of Intangible Assets (Part I)
Article:
This two-part article examines cost recovery of intangible asset expenditures. Part I summarizes the applicable capitalization regulations, Sec. 197 cost recovery and general Sec. 167 amortization rules
Published on July 13, 2010
Royalty Payments Not Subject to Capitalization Under Sec. 263A
Article:
A recent decision provides a potential opportunity for taxpayers that will incur royalty payments to structure the agreements in such a manner that they can immediately deduct royalty costs instead of capitalizing them under Sec. 263A.
Published on September 01, 2010
IRS Issues Prop. Regs. on Capitalization of Improvements to Property
Article:
Proposed regulations under Sec. 263(a) clarify the treatment of expenditures incurred in selling, acquiring, producing, or improving tangible assets.
Published on May 14, 2010
Unit of Property for Network Assets
Article:
Treasury issued proposed regulations under Secs. 162 and 263(a) providing guidance on the capitalization and deduction of costs relating to tangible property. Included in these regulations are the “repair regulations,” a comprehensive set of rules for determining whether costs incurred for tangible property...
Published on January 28, 2011
Could Forgetting to Include the Effect of UNICAP Put Accounting Method Changes at Risk
Article:
Taxpayers making automatic accounting method changes that affect capitalizable costs should consider the uniform capitalization rules of Sec. 263A and the related regulations (UNICAP rules
Published on April 27, 2012
IRS Issues Fifth Directive on the Allocation of Mixed Service Costs
Article:
The IRS has been scrutinizing how taxpayers have allocated mixed service costs to self-constructed assets under Sec. 263A.
Published on January 28, 2011
To Capitalize or to Expense How Sec. 263A Treats Royalties
Article:
The tax treatment of royalty payments—to capitalize or to expense—depends on the terms of the royalty agreements and, in some situations, the Sec. 263A uniform capitalization rules
Published on January 28, 2011
Sales-Based Royalties and Vendor Allowances
Article:
Proposed regulations would allocate sales-based royalties and vendor allowances to property sold during the tax year. The preamble indicates that the intention of the proposed regulations is that neither sales-based royalties nor sales-based vendor allowances should adjust the value of ending inventories.
Published on October 04, 2011
IRS Provides Safe-Harbor Methods for Auto Dealers Using UNICAP
Article:
Rev. Proc. 2010-44 resolves some of the issues raised by TAM 200736026 involving UNICAP issues affecting automobile dealerships; specifically, whether the installation of parts on customer-owned vehicles, and on taxpayer-owned vehicles, constitutes “production” for purposes of the UNICAP regulations.
Published on February 01, 2011
Accounting Method Changes Under the Tangible Property Regulations
Article:
This article details the method change rules under the current automatic consent procedural guidance and discusses the method changes that would be necessary to early adopt provisions of the temporary regulations.
Published on January 11, 2013
New IRS Audit Technique Guide for Examination of Repair and Maintenance Costs
Article:
The author reviews the IRS's new audit technique guide for examination of repair and maintenance costs. To be prepared for a potential IRS examination, taxpayers should ensure that the proper determination has been made with respect to unit of property and what is considered a repair and maintenance cost and should
Published on February 01, 2011
Homebuilder Status
Article:
A homebuilder’s home construction contracts are exempt from the long-term contract provisions of Sec. 460 and so are not subject to the percentage of completion method for regular tax or AMT purposes or to the lookback rules for either regular tax or AMT purposes. Further, a home construction contract is
Published on June 10, 2010
Transfer Pricing The New Temporary Cost-Sharing Regs.
Article:
On December 31, 2008, the IRS introduced new temporary cost-sharing regulations (T.D. 9441) that replace the old cost-sharing regulations introduced in 1995.
Published on January 28, 2011
Partnership Structural Changes Deductibility of Expenses
Article:
This item examines several partnership restructuring transactions and discusses the circumstances in which a restructuring expense can be deducted and amortized under Sec. 709 or must be capitalized under Regs. Sec. 1.263(a)-5(a).
Published on January 28, 2011