01 October 2025 IRS and Treasury finalize regulations modifying the interest capitalization requirements for affected improvements The IRS and Treasury Department on October 1, 2025, finalized regulations (TD 10034) to remove the associated property rule for improvements to real property (Treas. Reg. Section 1.263A-11(e)(1)(ii)(B)) and tangible personal property (Treas. Reg. Section 1.263A-11(e)(1)(iii)) for property temporarily withdrawn from service. The final regulations make only minor clarifying changes to the proposed regulations (see Tax Alert 2024-1010) that were issued following a long-standing Federal Circuit decision in Dominion Resources, Inc. v. United States, 681 F.3d 1313 (Fed. Cir. 2012). A Tax Alert is forthcoming. Document ID: 2025-1983 |
