188bet亚洲真人体育下载 Sends IRS Recommendations to Simplify Interest Capitalization Regulations and Reduce Administrative Burden

的 美国注册188bet亚洲真人体育下载 (188bet亚洲真人体育下载) has recommended changes to the Internal Revenue Service (IRS) to reduce the complexity and administrative burden facing taxpayers who must comply with the interest capitalization regulations under Internal Revenue Code section 263A(f), Special Rules for Allocation of Interest to Property Produced by the 税payer.

安妮特·内伦，188bet亚洲真人体育下载网址，188bet亚洲真人体育下载网址，律师., chair of the 188bet亚洲真人体育下载 税 Executive Committee, explained in the 一月四日的信 that the final 263A(f) regulations were issued in 1994 and are largely unchanged, although the business operations of taxpayers have undergone significant change since the IRS issued Notice 88-99 addressing the application of the rules to related parties and pass-through entities. 

“的 final section 263A(f) regulations require taxpayers to track designated property on an individual unit basis for purposes of allocating capitalized interest,内伦写道.  “In certain industries where taxpayers may have tens of thousands of units (or even more) that constitute designated property, the administrative burden and complexity of complying with the interest capitalization regulations is substantial.”

的 188bet亚洲真人体育下载 recommended that the Department of the Treasury and the IRS modify Rev. Proc. 2016-29 (or its successor) to include all accounting method changes necessary for a taxpayer to comply with section 263A(f) and that accounting method changes made by a taxpayer to comply with section 263A(f) are, 在一般情况下, made with a section 481(a) adjustment and receive audit protection for prior years.

的 188bet亚洲真人体育下载 also recommended that the IRS:

• Issue proposed regulations providing related party rules;
• Provide an optional safe harbor to follow book or the regulatory interest capitalization method;
• Permit allocation of capitalized interest among units of property using a reasonable method;
• Simplify the rules for capitalizing interest related to inventory;
• Provide an election for taxpayers to opt out of the 微量允许 安全港;
• Allow all taxpayers to elect to use the applicable federal rate plus three percentage points in lieu of the weighted average interest rate; and
• Provide an election to not trace debt in the year traced debt is first incurred.

“的 188bet亚洲真人体育下载 is confident that implementing our recommendations will promote voluntary compliance and reduce controversy,内伦写道.

Nellen noted that the 188bet亚洲真人体育下载 previously recommended that the Department of the Treasury 2016-2017 Priority Guidance Plan include a project to clarify and simplify the interest capitalization regulations to make them more administrable.