At the recent ABA tax division meet, Scott Dinwiddie, Special Counsel for the IRS Office of Associate Chief Counsel (Income Tax and Accounting), indicated that the IRS does not expect perfection in compliance with the new uniform capitalization (UNICAP) rules. Nevertheless, at least for the time being, the IRS does expect general compliance.
The new rules, which became effective January 1, 2012, are complex; however, they affect the vast majority of businesses across most business sectors. We will be discussing the new UNICAP rules during our Year-end Annual Tax Seminars. If you have questions about the UNICAP rules or other tax issues, please call our tax department at (781) 407-0300.