Ambridge Partners Introduces Placed in Service Tax Insurance Policy
4/28/2003
(New York, April 28, 2003) Ambridge Partners LLC (“Ambridge”) today introduced its Placed in Service Tax Insurance policy. This product has been developed to address the concern of a taxpayer surrounding a potential determination by the IRS that one or more of its assets has either failed to be “placed in service” at a specific point in time, or at all, thus causing potentially serious tax consequences. “This product is another example of how Ambridge’s tax insurance policies can be utilized to provide certainty for tax issues which revolve around very 'facts and circumstances' based determinations”.
The Placed in Service Tax Insurance policy can address two risks in respect of bonus depreciation laws enacted by Congress in 2002 and 2003. First, as the January 1, 2005 or 2006 deadline approaches, taxpayers will predictably rush to place assets into service. In many cases, there will be a risk that this did not in fact occur (i.e., the asset was actually placed into service after the cut-off date) which would render bonus depreciation unavailable. Second, there are a number of taxpayers who placed assets into service in 2001 who are concerned that they did so before September 11th, in which case bonus depreciation is not available. The PSI is structured to address these concerns, even though, in the latter case, taxpayers will already have filed their tax returns for 2001.
Ambridge’s new product can also be used in connection with certain tax credits that require an affirmative finding that a particular asset was placed in service by a particular date. Two examples are the nonconventional fuels credit under Section 29 of the Code and the historic rehabilitation credit under Section 47 of the Code. Each of these credits has particular requirements for when an asset must be placed in service. If the appropriate requirements are not met, the taxpayer is ineligible to claim the credit.
For more information about the tax issue to which the product is designed to respond, policy forms, applications or broker informational packets, please contact Ambridge at 212.871.5400 or email us at
info@ambridgepartners.com.
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