Section 263A contains the “uniform capitalization rules,” and generally provides that the direct and indirect costs of producing tangible personal property must be capitalized rather than expensed in ...

In early September, I published an article seeking guidance from the IRS on how to implement the new capitalization rules under IRC Section 174, which was effective on Jan. 1, 2022. Much to my ...

More than one‐third of the world's population uses a writing system that includes both uppercase and lowercase letter forms. In these writing systems, capitalization is the use of an uppercase form ...

The Tax Cuts and Jobs Act of 2017 (TCJA) introduced significant changes to the tax treatment of specified research and experimentation (SRE) expenditures. Historically, companies were able to ...

The Thin Capital Rules were introduced to prevent abuse of tax deductions with respect to interest paid on a loan made by a non-resident investor that controls a Japanese business operator. The policy ...

More than one-third of the world’s population uses a writing system that includes both uppercase and lowercase letter forms. In these writing systems, capitalization is the use of an uppercase form ...