- 8 - in service after December 31, 1985. The repeal was subject to a limited number of transitional ITC rules. TRA section 204(a), 100 Stat. 2146, contains a number of specific transition rules. There are also three general transition rules contained in TRA section 203(b), 100 Stat. 2143.5 TRA section 211 generally repealed the regular investment tax credit by adding section 49 to the Code. See TRA sec. 211(a). Section 49(e) provides an exception for “transition property”, which is defined as property placed in service after December 31, 1985, to which the amendments made by TRA section 201, 100 Stat. 2121, do not apply. Sec. 49(e)(1). World Headquarters Rule One of the transitional rules in TRA section 204(a) deals with property used in a leased building that serves as “world headquarters” of the lessee and its affiliates. TRA section 204(a)(7) provides: (7) Certain Leasehold Improvements.--The amendments made by section 201 shall not apply to any reasonable leasehold improvements, equipment and furnishings placed in service by a lessee or its affiliates if-- (A) the lessee or an affiliate is the original lessee of each building in which such property is to be used, 5The rules found in TRA sec. 203(b) are known as the binding contract rule, the self-constructed property rule, and the equipped building rule. See TRA sec. 203(b)(A), (B), and (C). Only the equipped building rule, TRA sec. 203(b)(C), is relevant to this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011