Corporations now included under Section 189
This article examines some of the issues, including the ''real property'' question, that corporations may encounter in implementing the provisions of Code Section 189 and its regulations. The extension of 189 to regular corporations represents a significant change in congressional intent, since it was originally enacted as a reform measure and is now primarily a provision to raise revenue at a time when Congress is facing a large dificit. Code Section 189 was conceived and enacted in haste, however, and this expansion will undoubtedly have an adverse impact on capital investment at a time when stimulation is needed for the economy as a whole. The workload of the courts and the Internal Revenue Service will certainly increase. Careful drafting of the regulations could anticipate potential issues and clarify them in the drafting stage. The meaning of real property, capitalization rate, capitalization period, and self-constructed assets all need to be carefully addressed. 18 references.
- Research Organization:
- Univ. of Ohio, Athens
- OSTI ID:
- 5199762
- Journal Information:
- Oil Gas Tax Q.; (United States), Vol. 32:2
- Country of Publication:
- United States
- Language:
- English
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