Alex Zakupowsky IIR Update Portland, Oregon June 18, 2014. Status of Industry Issue Resolution Projects. Electric T&D – Rev. Proc. 2011-43, Issued August 11, 2011 Revision in Process Do not expect before early 2013 Now, fourth quarter 2013 Now, 2014 Behind Gas T&D Electric Generation
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Alex ZakupowskyIIR UpdatePortland, OregonJune 18, 2014
Timing of Full Implementation
Revenue procedure provides:
For the first three taxable years ending on or after December 31, 2010, a taxpayer using the transmission and distribution property safe harbor method provided by this revenue procedure may determine the percentage of a unit of linear property replaced on the basis of an average circuit within a county.
Interpreted as applicable through 2013.
IRS has now promised further delay (2016?)
Unit of Property
Each asset would need to go into a GAA to allow the taxpayer to turn off the GAA election and recognize loss when there is a capital replacement
IRR can allow determination of repair or capital first and then that determination drives recognition of gain or loss.
Treas. Reg. §1.263(a)-3(g)(2).
Miller & Chevalier
655 15th Street, N.W.
Washington, D.C. 20005