Final Regs. on depreciation recapture allocations

Article Abstract:

New final Regulations introduced by the IRS provide clarifications regarding depreciation recapture allocation in a partnership. The objective of the Regulations is to allocate depreciation recapture to partners who made prior depreciation or amortization deduction claims on disposed property. The Regulations stipulate that the depreciation-recapture share of a partner is the lesser of the partner's portion of the aggregate gain on the disposition of the property or the share of the depreciation or amortization from the property. The final Regulations also indicate that a partner's share of depreciation or amortization from property contributed under Sec 704(c) covers the allowed or allowable pre-contribution depreciation or amortization. The share is lowered by curative and remedial allocations, which in turn raise the share of the non-contributing partner.

Taxation, Partnership, Partnerships, Depreciation, Recapture (Taxation), Allocation (Taxation), Tax allocation

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National Nexus Program for resolving past state tax liabilities

Article Abstract:

Voluntary disclosure programs seek to inspire companies with tax liabilities into disclosing their identities by limiting the period under which they should be penalized and by waiving some or all of all the penalties or interest. Taxpayers often choose to disclose to limit past liability, to clarify its tax reporting position or in response to external events. Voluntary disclosure programs come in two forms, namely, state-by-state disclosure and the MTC National Nexus Program. Under the latter, the Nexus Program staff are on hand to help nonfilers anonymously resolve their tax liabilities simultaneously with multiple states. The MTC acts as an 'honest broker' between the nonfiling company and the state for them to agree to a mutually satisfactory settlement.

Public Finance Activities, Corporate Tax Evasion & Penalties, Analysis, Management, Liabilities (Accounting), Corporate taxes, Disclosure statements (Accounting), Tax collection

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