LeasingNotes: Revenue Ruling 55-540 Archives

Revenue Ruling 55-540 Archives

Apr26	Economic substance doctrine Shawn Halladay April 26, 2006 Know More: Leasing, Leasing industry, Revenue Procedure 2001-28, Revenue Ruling 55-540, Tax benefits, Tax leases 2.0, Tax benefits It may not seem like a big deal, but codification of the economic subtstance doctrine is an issue on which it is worth keeping an eye, as it has the potential to disrupt our business. Continue Reading Posted at 2:58 PM \| Permalink \| Comments
Feb 7	Tax lease characterization Shawn Halladay February 7, 2006 The ultimate tax characterization of a lease lies with the tax courts, which consider all the economic characteristics of the transaction and how they relate to the criteria established by the IRS. Continue Reading Posted at 8:03 AM \| Permalink \| Comments
Feb 6	More tax lease guidelines Shawn Halladay February 6, 2006 The ultimate characterization of a lease as either a tax lease or nontax lease is not based on the tax code, per se. Instead, the criteria the IRS uses come from Revenue Ruling 55-540 (55-540) and Revenue Procedure 2001-28 (formerly Revenue Procedure 75-21). Continue Reading Posted at 8:36 AM \| Permalink \| Comments
Feb 3	Tax lease guidelines Shawn Halladay February 3, 2006 Entitlement to the depreciation is not an issue when the user of the asset also is the owner. In leasing, however, the owner (lessor) is not the user (lessee). This bifurcation of use and ownership has caused the IRS to scrutinize utilization of the tax benefits in lease transactions. Continue Reading Posted at 7:49 AM \| Permalink \| Comments
Feb 2	Is it a tax lease? Shawn Halladay February 2, 2006 Tax ownership is not as clear cut as the lease characterization of FASB 13. When determining ownership, the tax courts have used a mix of Revenue Ruling 55-540, Revenue Ruling 01-28, and prior court cases. Continue Reading Posted at 8:12 AM \| Permalink \| Comments

Revenue Ruling 55-540 Archives

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