This case is certainly an indication that field agents are looking deeper into a taxpayer's application of simplified methods when it comes to allocating
uniform capitalization costs.
supportive expenses to a class of gross income narrower than all gross income, a more favorable apportionment may be achieved for FTC limitation purposes.
The regulations contain no examples of allocating
capital gain under a power to adjust.
Triarc said it had also been advised that although this is one permissible method of allocating
tax basis, it may not be the only possible way to allocate tax basis.
Presumably, the same methods of allocating
costs between ending inventory and cost of goods sold should be acceptable when allocating
The property's basis would be treated as equal to its FMV at contribution for the purpose of allocating
items to the noncontributing partners.
Here's one method of allocating
City of Emeryville--The Waste Board approved allocating
$25,000 to have rubberized mats installed under and around playground equipment at Stanford Avenue Park using approximately 3,000 waste tires.
Reciprocal agreements: Before allocating
income to a particular nonresident state, taxpayers should check whether that state has a reciprocal exemption agreement with their resident state.
Rather, it said section 482's effectiveness in allocating
income and expense items when foreign corporations are involved would be undermined significantly if section 881 required actual payment.
Electing out of the deemed allocation rules does not prevent a transferor from allocating
his or her available GST exemption, such as when making a partial allocation on a timely filed Form 709 or by making a late allocation under Regs.
There is growing concern on the part of states' attorneys general that some charitable organizations have been "too liberal" in allocating
costs to program expenses (instead of to administration or fund-raising), particularly costs to educate the public.
Under the safe--harbor pro visions for allocating
nonrecourse deductions in Regs.
The Service buttressed its conclusion by referring to Department of Labor (DOL) Employee Benefits Security Administration, Field Assistance Bulletin 2003-3 (issued 5/19/(13), which sets forth guidelines for allocating
administrative expenses among plan participants in a defined contribution plan.
The IRS issued final regulations on directly allocating
unrelated party interest expense to interest income from related controlled foreign corporations (CFCs).