If a taxpayer changes to the design-by-design method, the section 481(a) adjustment equals the difference between (i) the total amount of package design costs subject to capitalization and not abandoned as of the beginning of the year of change that were deducted or amortized
in tax years before the year of change, and (ii) the amount of amortization that would have been allowed if the design-by-design method had been used.
Start-up and organizational expenditures incurred on or before that date continue to be eligible to be amortized
over a period not to exceed 60 months; however, they are still considered in applying the $50,000 deduction phaseout.
The assets can be amortized
using the old or the new law-- whichever yields greater tax savings.
If the hedging rules did apply, the payment should have been amortized
under the terms of the bond and the period to which the hedge related.
197, and the payments of the covenant would therefore be amortized
over the life of the agreement.
For CMOs carried at amortized
cost, the task force decided: At the purchase date, calculate an effective yield based on the purchase price and anticipated future cash flows.
Alternatively, both tranches can be amortized
, or redeemed for cash at any time at the company's option, at 105 percent of par, plus accrued interest.
The amount of OID amortized
each year for both taxable and tax-exempt bonds increases the taxpayer's basis in the bonds.
503 US 79 (1992), the IRS has contended that many expenditures previously considered currently deductible must be capitalized, and cannot be depreciated or amortized
The weighted average amortized
loan-to-value ratio (LTV) for the sub-group I-A loans is 82.
The number of months (not less than 60) over which the expenditures are to be amortized
38 is amortized
with zero defaults and zero prepayments.