Agent's view: According to the agent, the taxpayer
allocates cost pools to projects, and ultimately expenses or capitalizes such costs using "costs drivers," which determine how costs are "driven" to different projects or codes.
With the adjustment power, the trustee could
allocate some of the capital gain to an income beneficiary, even though that gain is principal.
This approach
allocates 100% of "premium" to operating units.
This raises numerous compliance issues and compounds the uncertainties CPAs face when they prepare gift tax returns and
allocate GST exemption.
This recapture rule applies to any section 467 rental agreement that is a leaseback or a longterm agreement that is not disqualified but which
allocates to any rental period fixed rent that, when annualized, exceeds the annualized fixed rent allocated to any preceding rental period.(79)
Thus, any other "facts and circumstances" method, such as specific identification, burden rate, standard cost or "other reasonable allocation methods," must
allocate costs to specific inventory items; see Regs.
* Compensation expense if the company
allocates the dividends to participants' accounts or if it pays them to participants out of a suspense account.
affiliated group must
allocate interest as a fungible expense on the basis of its worldwide assets.
Thus, without a consistency requirement, a trustee's decision to
allocate capital gain from year to year could be purely tax-motivated.
Method 1:
Allocate on the basis of activity-based costs.
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.
26.2642-2(a)(1), for lifetime transfers, the value of the property to which the taxpayer
allocates the GST exemption is its value at the transfer date, if the GST exemption is automatically allocated (or is allocated) on a timely filed Federal gift tax return.
