The Internal Revenue Service has published guidance for taxpayers in the telecommunications industry with the aim of resolving long-running tax disputes involving the capitalization and depreciation of network assets.

The three revenue procedures issued on Monday resulted from two Industry Issue Resolution Program projects that were recently completed. The IIR Program resolves business tax issues common to significant numbers of taxpayers, usually within a specific industry, through new and improved guidance. 

“This program strives to find the best way to resolve outstanding tax disputes affecting industries,” said IRS Commissioner Doug Shulman in a statement. “Through guidance, we seek to eliminate confusion and minimize conflict while providing taxpayers greater certainty.”

Differences regarding the appropriate manner to capitalize network asset repair and replacement costs have led to $3.6 billion in accounting method disputes between taxpayers and the IRS affecting 80 percent of the telecom industry. The capitalization project is designed to minimize these disputes. A related wireless depreciation project aims to minimize depreciation disputes involving the recovery period of assets in the wireless telecom sector.  In 2007 alone, the wireless sector placed in service $8 billion of new fixed assets.

On Monday, the IRS released Revenue Procedure 2011-28 for the wireless telecom sector, providing two alternative safe-harbor methods for determining the amount of network asset repair and replacement expenditures that must be capitalized. The IRS also released Revenue Procedure 2011-27, which provides similar safe harbors for “wireline” telecom carriers, or firms with landline networks.

Another revenue procedure issued Monday, Revenue Procedure 2011-22, provides a safe-harbor method for determining the recovery period for depreciation of certain tangible assets used by wireless telecommunications carriers.

This published guidance results from a combined effort involving representatives of the telecommunications industry and the IRS and Treasury Department officials to resolve areas of long-standing tax controversy in a manner that provides consistency, efficient use of government and taxpayer resources, along with greater certainty. 

Project selections are based on the criteria set forth in Revenue Procedure 2003-36. For each issue selected, a multi-functional team of IRS, Chief Counsel and Treasury personnel is assembled. The teams gather and analyze the relevant facts from industry groups and taxpayers for each issue and recommend guidance.

Requests for guidance on tax issues under this program can be submitted at any time to Submissions received are reviewed semi-annually.

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