This approach
allocates 100% of "premium" to operating units.
Any method that does
allocate costs to specific inventory items may be compared to any other permissible method that
allocates costs to specific inventory items to determine reasonableness (this is hardly ever the case).
A donor cannot
allocate GST exemption to an inter vivos transfer (a transfer the donor makes during his lifetime) if the property would be included in his or her spouse's gross estate (other than under IRC section 2035) if the donor died immediately after the transfer.
[sec.] 1.861-10T(c) contains a new rule for integrated financial transactions that
allocates interest expense directly to income from an investment funded with amounts borrowed for the purpose of acquiring the investment.
Although a trustee who
allocates capital gain to trust income with a power to adjust must do so "reasonably and impartially," the regulations neither define nor illustrate this concept.
The principal reason costs may be higher is because the expense amount a company records for new shares will be based on the fair market value of the shares the plan
allocates to participant accounts--measured at the time of allocation--rather than on the amount of the cash contribution the company makes to the ESOP to repay the loan.
Because it is impracticable (or impossible) to trace and
allocate each individual discount through the system, some sort of allocation method should be allowed as long as such method clearly reflects income and is consistently applied.
While the rules probably do correct the failure to properly
allocate the exemption to trusts meant to benefit skip persons, they can also result in wasting the GST exemption, by automatically allocating it to trusts not intended to benefit skip persons.
A corporate general partner or any limited partner cannot
allocate its share of partnership interest expenses between foreign- and U.S.-source income for foreign tax credit (FTC) purposes if its partnership interest is less than 10%.
To
allocate tolerable misstatement using our approach, a Delphi team is selected.
Larry and the retail sales corporation could
allocate more of the sales price to the land to increase the portion of the gain that is capital gain.
The Internal Revenue Service allocated rents to Central de Gas under section 482, which grants it authority to
allocate items of income and expense among related parties to reflect income properly.
Taxpayers should attempt to arrange their business and other economic activities to effectively minimize the income they apportion and
allocate to states with high marginal tax rates.
Under the IRC, dividends on shares held by an ESOP that have been allocated to participant accounts cannot be used for debt service unless the employers
allocate to those participants shares whose dollar value is no less than the dollar value of the dividends that were used for debt service.
The deemed-allocation rules applicable to indirect skips were designed to simplify the process, by removing the affirmative election to
allocate the GST tax exemption, especially in instances in which the allocation was intended to be made, but inadvertently omitted.
