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Election Allows for Enhanced Utilization of Tax Attributes |
Many companies are experiencing current year net operating losses (NOLs) due to the recession. Consequently, it may make sense for these companies to consider accelerating taxable income in order to enhance utilization of tax attributes such as NOLs and foreign tax credits (FTCs).
An election under IRC section 59(e) provides companies significant flexibility in managing taxable income. Made on an annual basis, the election defers deductions by capitalizing otherwise deductible research and experimentation and certain other costs and amortizing them over up to 10 years. Potential benefits include the reduction of alternative minimum tax, utilization of expiring FTCs, management of built-in-losses, and refreshment of NOL carryovers. In addition, IRC section 59(e) allows taxpayers to selectively limit capitalization to a specific dollar amount of qualifying expenses on an annual basis. We recommend companies evaluate their qualification for and the potential benefits available from an election under IRC section 59(e).
Source: RSM McGladrey |