Controversies overapplying Section 263A capitalization rules

July 2008
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Controversies overapplying Section 263A capitalization rules

At a glance

This PwC article analyzes two Section 263A issues: Contingent royalties and negative costs.

IRS scrutiny of uniform capitalization issues increases the need for taxpayers to review their Section 263A computations, particularly with respect to such items as contingent royalties and negative costs.