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The final regulations require capitalization of (i) an amount paid to acquire any intangible; (ii) an amount paid to create certain but not all intangibles; (iii) an amount paid to create or enhance a "separate and distinct intangible asset"; and (iv) an amount paid to create or enhance a "future benefit," but only under certain circumstances.
According to NAREIT, the REIT industry is poised to continue its rapid growth through 1997, given the combination of strong, consistent total return performance, dramatic increases in market capitalization and liquidity as well as heightened interest from institutional and individual investors.
While the rules regarding capitalization of environmental treatment costs appear consistent with IRS and Financial Accounting Standard Board pronouncements, the TAM's treatment of remediation costs conflicts with the FASB's.
With respect to transactions in the first two categories that require capitalization, the ANPRM specifies which types of costs taxpayers will have to capitalize.
These regulations would require interest capitalization on improvements not classified as buildings and with class lives under 20 years, including items such as fences, paved parking areas, railroad tracks, bridges, tunnels, towers, greenhouses, grain storage bins and the like.
MICO's capitalization improved in 2005 as demonstrated by an increase in its Best's Capital Adequacy Ratio (BCAR), which measures capitalization on a risk-adjusted basis.
As for the other costs, the IRS concluded that capitalization might be required, depending on the facts of the case.
We believe that the diversity and training of our members enable us to bring an important, balanced, and practical perspective to the need for guidance on the deductibility or capitalization of expenditures in the aftermath of the INDOPCO decision.
The risk-based capitalization, as measured by Best's Capital Adequacy Ratio (BCAR), has demonstrated the strengthened capitalization.
The Eighth Circuit's Wells Fargo decision is important for all taxpayers involved in acquisitions, reorganizations or other capital transactions that provide future benefits, as well as those involved in other projects that may be subject to capitalization (such as enterprise resource planning implementation and Website design).
1039 (1992), in which the Supreme Court, not surprisingly, required the capitalization of the costs of a friendly merger that changed the corporate structure and promised long-term synergistic benefits to the taxpayer.
The ratings also acknowledge the company's satisfactory risk-based capitalization and well established profile in Hong Kong, Macau and Mainland China.