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Internal Revenue Service › Capitalized Cost

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Fenwick & West LLP

Treatment of Capitalized R&D Costs under Section 174 on a Disposition of IP: The Other Shoe to Drop

Fenwick & West LLP on

One of the more significant issues that taxpayers and tax practitioners have faced in recent months is the Tax Cuts and Jobs Act’s (TCJA) amendment to Section 174, requiring capitalization of previously deductible R&D and...more

Troutman Pepper

When Can Capitalized Transaction Costs Be Recovered? Recent LB&I Transaction Unit Provides Insight

Troutman Pepper on

Taxpayers typically incur significant transaction costs when undergoing a transaction involving a restructuring, acquisition, disposition, sale of assets, or sale of stock. The default rule under section 263 is that all...more

Shumaker, Loop & Kendrick, LLP

Banks Not Required to Capitalize OREO Costs

Shumaker, Loop & Kendrick, LLP on

The Office of the Chief Counsel of the Internal Revenue Service has issued a Legal Memorandum (Number AM2013-001, dated March 1, 2013) (the “Memorandum”), which has important implications and represents a victory for lenders...more

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