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... Read More
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,... Read More
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... Read More