Publication 535 |
2000 Tax Year |
Capitalization of Interest
Under the uniform capitalization rules, you generally must
capitalize interest on debt equal to your expenditures to produce real
property or certain tangible personal property. The property must be
produced by you for use in your trade or business or for sale to
customers. You cannot capitalize interest related to property that you
acquire in any other manner.
Interest you paid or incurred during the production period must be
capitalized if the property produced is designated property.
Designated property is any of the following.
- Real property.
- Tangible personal property with a class life of 20 years or
more.
- Tangible personal property with an estimated production
period of more than 2 years.
- Tangible personal property with an estimated production
period of more than 1 year if the estimated cost of production is more
than $1 million.
Property you produce.
You produce property if you construct, build, install, manufacture,
develop, improve, create, raise, or grow it. Treat property produced
for you under a contract as produced by you up to the amount you pay
or incur for the property.
Capitalized interest.
Treat capitalized interest as a cost of the property produced. You
recover your interest when you sell or use the property. If the
property is inventory, recover capitalized interest through cost of
goods sold. If the property is used in your trade or business, recover
capitalized interest through an adjustment to basis, depreciation,
amortization, or other method.
Partnerships and S corporations.
The interest capitalization rules are applied first at the
partnership or S corporation level. The rules are then applied at the
partners' or shareholders' level to the extent the partnership or S
corporation has insufficient debt to support the production or
construction costs.
If you are a partner in a partnership or a shareholder in an S
corporation, you may have to capitalize interest you incur during the
tax year for the production costs of the partnership or S corporation.
You may also have to capitalize interest incurred by the partnership
or S corporation for your own production costs. You must provide the
required information in an attachment to the Schedule K-1 to
properly capitalize interest for this purpose.
Additional information.
The procedures for applying the uniform capitalization rules are
beyond the scope of this publication. For more information, see
section 1.263A-8 through 1.263A-15 of the regulations and
Notice 88-99 (as amended by Announcement 89-72). Notice
88-99 is in Cumulative Bulletin 1988-2. Announcement
89-72 is in Cumulative Bulletin 1989-1.
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