The AICPA tax
executive committee in April commented on
regulations the IRS and the Treasury
Department had proposed regarding the
deduction and capitalization of
expenditures for acquiring, creating or
enhancing intangible assets (www.cpa2biz.com/ResourceCenters/Tax/).
The committee said that in general,
the proposed regulations substantially
simplify and resolve the numerous
capitalization issues generated by the
[U.S.] Supreme Courts decision in Indopco,
Inc. v. Commissioner, 503
US 79 (1992) and that it supported
this initiative. The committee also
expressed policy and/or technical
concernsand requested
guidanceabout certain aspects of
the proposed regulations, including the
so-called 12-month rule that governs
capitalization of amounts paid to create
or enhance intangible rights or benefits;
the treatment of enterprise resource
planning software implementation costs;
and the deductibility or capitalization
of transaction costs related to acquiring
or expanding a trade or business. In April and May the tax
executive committee also expressed to
Congress its support for two tax
simplification bills in the House of
Representatives: HR 22, the Individual
and Small Business Tax Simplification Act
of 2003 and HR 285, the Fairness,
Simplification and Competitiveness for
American Business Act of 2003 (www.aicpa.org/download/news/2003_0507.pdf).
The legislation would simplify IRC
sections pertaining to individuals, small
businesses and U.S. companies doing
business in foreign countries. The
committees comments on the two
bills are available on the Web at www.cpa2biz.com/ResourceCenters/Tax/Legislative%2C+Administrative%2C+Judicial/HoughtonBill.htm
and www.cpa2biz.com/ResourceCenters/Tax/International/HR285.htm,
respectively.
The Treasury
Department and the IRS issued a revenue
procedure in May providing guidance to
taxpayers electing to apportion their
interest expense on the basis of the fair
market value of their assets (www.ustreas.gov/press/releases/js359.htm).
The guidance affects taxpayers who want
to apply a credit to their U.S. tax
liability for income taxes they paid to a
foreign country or U.S. possession.
The IRS offers, for
the 13th consecutive year, a series of
nationwide tax forums. This years
presentations began in July and will
continue through September. The remaining
three-day sessionsone each in
Atlanta, St. Louis, San Antonio and Las
Vegaswill offer tax professionals
information on filing returns
electronically, earning CPE credits,
resolving disputes between clients and
the commission and keeping abreast of tax
law changes. Additional information and
registration instructions are available
at www.irs.gov/taxpros/article/0,,id=97192,00.html.
The U.S. Senate in
May confirmed President George W.
Bushs appointment of Mark W.
Everson, CPA, to a five-year term as the
46th IRS commissioner (www.irs.gov/irs/article/0,,id=98192,00.html).
Prior to his appointment, Everson had
held senior posts in several federal
government agencies and major U.S. and
European corporations.
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