Deduct or Capitalize? New Definition for Property Expenditures

Temporary Regulations, effective January 1, 2012, provide guidance on IRC Sections 162 and 263(a), address when amounts paid to acquire, produce, or improve tangible property are deductible or capitalizable. The Regulations modify the "general plan of rehabilitation" doctrine, define a safe...

Sutherland Legal Alert: Bringing Certainty to an Uncertain Tax Position: IRS LB&I Directive Addresses Partial Worthlessness Deductions Claimed by Insurance Companies

By Bill Pauls and Michael Miles, Sutherland Asbill & Brennan LLP On July 30, 2012, the IRS Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions claimed by insurance companies. In brief, the guidelines...

Sutherland Legal Alert: Bringing Certainty to an Uncertain Tax Position: IRS LB&I Directive Addresses Partial Worthlessness Deductions Claimed by Insurance Companies

By Bill Pauls and Michael Miles, Sutherland Asbill & Brennan LLP On July 30, 2012, the IRS Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions claimed by insurance companies. In brief,...

Article on New Sentencing Guidelines on Unclaimed Deductions and Credits

I have posted previously on the unclaimed deduction / credit issue and the recent Guidelines resolution of the issue. The 2013 Guidelines provision on this issue is here §2T1.1., Commentary par. 3, here , which provides: 3. Unclaimed Credits, Deductions, and Exemptions.—In determining the...