AICPA Wants IRS to Provide Property Capitalization Rules That Are Clear Enough for CPA Exam Review Materials


Despite an IRS proposal of new regulations to limit confusion over capitalizing and depreciating tangible property, the AICPA remains critical of the complexity.  Especially troubling is the burden placed on small businesses for obtaining accounting expertise to address capital expenditures.  The AICPA wants definitive regulations that provide clear principles suitable for CPA review materials.

According to the AICPA, the new rules introduce additional complications instead of unambiguous testing procedures.  Accounting becomes an inexact process when it resorts to the “facts and circumstances” approach of many tax regulations.  The AICPA prefers to lift the controversy about capital costs by making the subject just as certain as plain accounting matters objectively addressed in study for CPA exam completion.

The new proposed IRS rules cause accountants to consider obscure factors about routine expenses.  For example, recurring property maintenance is scrutinized to determine if capitalization is required for any of that activity. Tax accountants are stuck with applying complex regulations to routine purchases of materials and supplies. This is a much more detailed process than CPA exam review about basic depreciation of capital expenditures.

The AICPA is concerned that small businesses face a very high hurdle regarding capitalization.  They need simplified depreciation rules. Instead, their tax advisers are going to require substantial details to apply regulations from CPA study to common and recurring costs.  Since small entities are the largest group of business taxpayers, a lack of clear depreciation standards impacts a lot of people and their CPAs.

Simplifying complex tax calculations is usually accomplished by introducing safe harbor methods. This has traditionally meant the application of de minimis rules for expensing small items regardless of whether they add to useful property life. Under this safe harbor, only sufficiently large expenditures that enhance property life are capitalized.

The new IRS regulations permit de minimis expenses only for businesses using accounting that meets Applicable Financial Statement standards.  This financial reporting requires preparation in accordance with US Generally Accepted Accounting Principles and filing with the US Securities and Exchange Commission or similar government agency.  Small companies typically do not meet this qualification because no other mandate exists for doing so.

The AICPA recommends using an alternative test for de minimis expenses.  The plan allows for de minimis eligibility based upon an aggregate dollar ceiling.  A potential measurement of this figure might entail comparison to some objective tax attribute, such as gross receipts.  This idea is designed to clarify definitions about capital costs for CPA review courses and provide some relief to

IRS Circular 230 Disclosure

Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication.

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IRS Circular 230 Disclosure
Pursuant to the requirements of the Internal Revenue Service Circular 230, we inform you that, to the extent any advice relating to a Federal tax issue is contained in this communication, including in any attachments, it was not written or intended to be used, and cannot be used, for the purpose of (a) avoiding any tax related penalties that may be imposed on you or any other person under the Internal Revenue Code, or (b) promoting, marketing or recommending to another person any transaction or matter addressed in this communication.


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