Omnibus Capitalization Proposals

This shelf project proposal covers several expenditures that are allowed as expenses as soon as they are incurred under current law but should be treated as capital expenditures. Given the treatment of debt financing, capitalization is needed to prevent negative tax or subsidy for investments, many with dubious merit. The expensing subsidy allows projects to go forward that would lose money in the absence of tax. Absence of pretax profit…
Andrews & Kurth Centennial Professor of Law, University of Texas at Austin - School of Law, USA
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