IRS Rules Salvage is Protected, Cost of Removal is Not

On October 15, the IRS issued PLR 202141001 for regulated electric utilities. In its ruling, the IRS reiterated earlier assertions that the net deferred tax asset (DTA) related to the cost of removal (COR) is not subject to normalization, but also added clarification that the deferred tax liability (DTL) and DTA from the salvage value is subject to normalization rules.

Vadim LantukhNovember 3, 2021tax, accounting, irs, rate regulated utilities, electric, regulated electric utilities, lucasys, lucasys tax, normalization, cost of removal, depreciation, tax systems, tcja, tax rate changes, utility industry

Cost of Removal, Normalization, and Other Thorny Issues for Utilities

On August 14, 2020, the Internal Revenue Service (IRS) issued PLR 202033002 to address outstanding ruling requests on the application of the Section 168 normalization rules to cost of removal (COR). The IRS concluded that the net deferred tax liability (DTL) created by COR is not protected by the normalization rules but did not provide guidance on the actual implementation of the ruling’s conclusions.

Vadim LantukhJanuary 5, 2021tax, accounting, software solutions, lucasys, lucasys tax, cost of removal, normalization, utility industry, rate regulated utilities, regulatory assets, regulatory rulings, irs, tax assets, enterprise, tax accounting systems, tax accounting software