- 14 - On the record before us, there is insufficient evidence of the type of substantial international operations required to justify classifying Payless’ corporate headquarters at Two Pershing Square a “world headquarters” as that term is used in TRA section 204(a)(7). Equipped Building Rule In the alternative, Payless argues that its expenditures qualify for ITC under the “equipped building rule”. TRA section 203(b)(1)(C) provides: (1) In general.--The amendments made by section 201 shall not apply to-- * * * * * * * (C) an equipped building or plant facility if construction has commenced as of [December 31, 19859], pursuant to a written specific plan and more than one-half of the cost of such equipped building or facility has been incurred or committed by such date. In order to qualify for transitional relief, Payless must show that: (1) Construction commenced by December 31, 1985; (2) Construction was pursuant to a written specific plan; and (3) More than one-half of the cost of the building, including its machinery and equipment, was incurred or committed 8(...continued) world headquarters. 9TRA sec. 211(a) amended subpt. E of pt. IV of subch. A of ch. 1 by adding a new sec. 49. Sec. 49(e)(1)(B) substituted “Dec. 31, 1985", for “Mar. 1, 1986", in sec. 203(b)(1)(C).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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