Ethan Yale

When Are Capitalization Exceptions Justified?

Tax Law Review


Normative capitalization would suspend deductions for every expenditure to the extent that it procures a benefit lasting beyond the taxable year in which the cost is incurred. A number of arguments have been advanced for departing from normative capitalization, including (1) that an inability to set rational depreciation schedules renders capitalization more distortive than expensing, (2) that capitalization and expensing lead to nearly identical results given certain steady-state investment patterns, and (3) that indirect costs should be expensed because it is too difficult to identify and allocate them among capital expenditures. This article examines these and other arguments and concludes that exceptions to normative capitalization can be justified only in limited instances, but that none of the arguments considered justify departing from normative capitalization to the extent commonly accepted.


Ethan Yale, When Are Capitalization Exceptions Justified?, 57 Tax Law Review 549–606 (2004).

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