However, the court did agree with Robinson that its royalty payments were not allocable
to inventory and therefore could be deducted.
to these agreements will be treated as advance trade discounts under Revenue Procedure 2007-53.
In general, the Temporary Regulations allow taxpayers to use any reasonable method to determine the portion of W-2 wages allocable
Thus, each owner is treated as having W-2 wages for the tax year only equal to the owner's allocable
share of the entity's W-2 wages for that year.
Independent manufacturers have proposed legislation to make payments directly to the states based on allocable
share, rather than to escrow accounts.
With diverted revenue included, the percentage of overhead allocable
to COPAR was higher than the actual experience.
Net income allocable
to common stockholders, adjusted for after-tax merger expense, was a record $9.1 million, or $0.61 per diluted share in the first quarter of 2018, compared to 2017 first quarter net income allocable
to common stockholders, adjusted for after-tax merger expense, of $5.5 million, or $0.46 per diluted share.
A CERIL is defined as the excess of the NOL for the tax year over the NOL for such tax year determined without regard to any allocable
interest deductions otherwise taken into account in computing such loss (Sec.
Hence, in order for specific identification of COGS to be required, the relevant information must be readily available and the taxpayer must be able, without undue burden or expense, to specifically identify COGS allocable
Under the arrangement, 98% of Castle Harbour's operating income was allocated to the Dutch banks; consequently, the same percentage of net book income (operating income reduced by expenses including an allocable
amount of depreciation) was allocated to the banks, representing their actual income from the Castle Harbour investment.
New analysis begins at this point with the introduction of section 263A, which requires the taxpayer to capitalize the direct costs of inventory and the inventory's proper share of those indirect costs--part or all of which are allocable
The company reported a net loss allocable
to common stockholders of $5.2 million, which includes depreciation and amortization of $8.7 million, compared to a net loss allocable
to common of $5.4 million for the second quarter of 2002.