Omnibus Capitalization Proposals

Abstract

This shelf project is part of series of proposals to capitalize investment expenditures that are deducted as soon as they are incurred under current law. This last-in-the-series, omnibus proposal would capitalize officer and employee compensation paid to investigate and effect a corporate acquisition, a change of capital structure, and a multiyear contract. Payments for termination of a contract would be amortized over the remaining life of the terminated contract. The proposal would capitalize the direct and indirect costs of exploration for and development of oil and gas or mineral deposits, expenses of large contracts to provide services, costs of depreciable property, and film and television production.

The proposal is made as a part of the Shelf Project, a collaboration by tax professionals to develop and perfect proposals to help Congress when it needs to raise revenue.