The company then applies this percentage to an actuarially set total "premium" cost for the company, and allocates
each operating unit its proportional share.
other reasonable methods must allocate
costs to specific inventory items.
A donor therefore must allocate
GST exemption to a gift to a trust even if the gift tax annual exclusion completely covers it.
If a taxpayer has a loss in a separate limitation category in a noncontrolled section 902 company as a result of interest expense apportionment it may elect to allocate
interest expense to any other separate limitation category that is in an excess credit position.
While this is not good news for existing irrevocable trusts, those drafting new trust instruments should Consider adding a provision that gives the trustee "the power to allocate
all or part of a capital gain to trust income."
* Compensation expense if the company allocates
the dividends to participants' accounts or if it pays them to participants out of a suspense account.
In another questionable stance, the IRS held in Letter Ruling 200144003 that a distributor of certain component products used in the manufacture of vehicles had to allocate
storage and handling costs to merchandise in transit, but not yet received.
The entity should allocate
other costs not identifiable with a particular component of the activity between fundraising and the appropriate program or management and general function.
However, Congress realized that tax advisers were often failing to properly allocate
the GST exemption to trusts ultimately intended to benefit skip persons.
partnerships is their ability to allocate
items of income, gain, loss and deduction among the partners in ratios that differ from those in the partners' capital accounts.
Thus, when a partnership interest is exchanged for debt, the partnership must recognize cancellation of debt income and allocate
it to its historical partners.
On first consideration, it might appear appropriate to simply allocate
aggregate preliminary materiality in proportion to the balances of the various financial statement elements.