- 35 - 1987); sec. 1.263A-1T(b)(2)(iii)(I), Temporary Income Tax Regs., 52 Fed. Reg. 29378 (Aug. 7, 1987). The production of real property includes the rehabilitation or improvement of an existing building. Sec. 263A(g)(1); sec. 1.263A-1T(a)(5)(ii), Temporary Income Tax Regs., 52 Fed. Reg. 10061 (Mar. 30, 1987); S. Rept. 99-313, supra at 143, 1986-3 C.B. (Vol. 3) at 143; Notice 88-99, 1988-2 C.B. 422. (1) Interest Expense Interest paid or incurred during the production period of real property must be capitalized under the special rules of section 263A(f). Sec. 263A(f)(1)(A) and (B)(i), (4)(A)(i). The interest to be capitalized includes (1) interest on any indebtedness directly attributable to production expenditures with respect to the real property, and (2) interest on any other indebtedness to the extent that the taxpayer’s interest costs could have been reduced if production expenditures had not been incurred. Sec. 263A(f)(2); sec. 1.263A-1T(b)(2)(iv)(A) and (B), Temporary Income Tax Regs., 52 Fed. Reg. 10063 (Mar. 30, 1987). The production period covers the period (1) beginning on the date on which production of the real property begins and (2) ending on the date on which the real property is ready to be placed in service. Sec. 263A(f)(4)(B); sec. 1.263A-1T(b)(2)(iv)(A), Temporary Income Tax Regs.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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