News & Analysis as of

Accumulated Deferred Income Tax (ADIT) Internal Revenue Code (IRC)

Holland & Knight LLP

Condemned to Lose Your ADIT?

Holland & Knight LLP on

In a private letter ruling, the IRS concluded that the condemnation of public utility property is in effect a "retirement" or "disposition" that requires the elimination of accumulated deferred income taxes (ADIT) associated...more

Eversheds Sutherland (US) LLP

Normalization ruling covers new ground on supplemental rate proceedings and depreciation-related section 481 adjustments 

On March 6, 2020, the Internal Revenue Service (IRS) released PLR 202010002, which provided the appropriate normalization treatment of infrastructure surcharges in supplemental rate proceedings as well as the proper...more

Eversheds Sutherland (US) LLP

IRS rules no violation of normalization requirements in computation of pro rata portion of ADIT used to reduce rate base

In a recent private letter ruling (PLR 201949006), the Internal Revenue Service (IRS) addressed the computation of the pro rata portion of accumulated deferred federal income tax reserve (ADFIT, together with the total...more

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