Allocation and Accounting Regulations (Treas. Reg. 1.141-6)

General Overview

On October 25, 2015, the Treasury Department released finalized regulations in T.D. 9741 to address allocation and accounting rules, including rules relating to undivided portion allocation, treatment of partnerships and certain remedial action matters, including anticipatory remedial actions. Click the following link (2015-27328 Allocation and Accounting Rules) to download the final regulations.

Resources

PLR 200441025 (Jun. 14, 2004): Parking ramp example with adjacent retail structure and a roof deck for future private business use.  Facilities are split into discrete portions.  For purposes of the roof deck, the discrete portion includes the additional costs needed for supporting future private business use construction.  Allocation of proceeds and equity using these discrete portions. Discussion of simultaneous governmental and private business use of parking deck and allocation of proceeds based on percentage of parking spaces used for private business use leases. Allocation of private payments to sources in the same percentage as parking spaces used for the good and bad purposes.  Allocation of private payments “to the extent that those expenses are directly attributable to the operation and maintenance of the parking ramp related to the use under the parking agreements.”

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