Tax Notes

The AICPA tax executive committee in April commented on regulations the IRS and the Treasury Department had proposed regarding the deduction and capitalization of expenditures for acquiring, creating or enhancing intangible assets ( ). The committee said that “in general, the proposed regulations substantially simplify and resolve the numerous capitalization issues generated by the [U.S.] Supreme Court’s decision in Indopco, Inc. v. Commissioner, 503 US 79 (1992)” and that it supported this initiative. The committee also expressed policy and/or technical concerns—and requested guidance—about certain aspects of the proposed regulations, including the so-called 12-month rule that governs capitalization of amounts paid to create or enhance intangible rights or benefits; the treatment of enterprise resource planning software implementation costs; and the deductibility or capitalization of transaction costs related to acquiring or expanding a trade or business.

In April and May the tax executive committee also expressed to Congress its support for two tax simplification bills in the House of Representatives: HR 22, the Individual and Small Business Tax Simplification Act of 2003 and HR 285, the Fairness, Simplification and Competitiveness for American Business Act of 2003 ( ). The legislation would simplify IRC sections pertaining to individuals, small businesses and U.S. companies doing business in foreign countries. The committee’s comments on the two bills are available on the Web at and , respectively.

The Treasury Department and the IRS issued a revenue procedure in May providing guidance to taxpayers electing to apportion their interest expense on the basis of the fair market value of their assets ( ). The guidance affects taxpayers who want to apply a credit to their U.S. tax liability for income taxes they paid to a foreign country or U.S. possession.

The IRS offers, for the 13th consecutive year, a series of nationwide tax forums. This year’s presentations began in July and will continue through September. The remaining three-day sessions—one each in Atlanta, St. Louis, San Antonio and Las Vegas—will offer tax professionals information on filing returns electronically, earning CPE credits, resolving disputes between clients and the commission and keeping abreast of tax law changes. Additional information and registration instructions are available at,,id=97192,00.html .

The U.S. Senate in May confirmed President George W. Bush’s appointment of Mark W. Everson, CPA, to a five-year term as the 46th IRS commissioner (,,id=98192,00.html ). Prior to his appointment, Everson had held senior posts in several federal government agencies and major U.S. and European corporations.

For single-click access to further coverage of the tax stories listed here, visit the Journal of Accountancy Web site at .


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