Form Ie-A - Intangible Expense - Application For Approval To Deduct
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1Please submit to:
Tennessee Department of Revenue
TN Department of Revenue
ATTN: Intangible Expense
Intangible Expense - Application for Approval to Deduct
P.O. Box 190644
Form IE-A
Nashville, TN 37219-0644 or to
Intangible.Expense@tn.gov
Taxpayer Name:
______________FEIN:_____________________
Intangible expense(s):
____________Federal form to be filed: ____________________
Name of affiliate in intangible transaction:
___________FEIN:____________________
Affiliate’s State/Country of incorporation or formation:
_______ Date:_____________________
If such expenses are paid to more than one affiliate, either submit a separate application for the expenses paid to each affiliate or attach schedules to this form
setting forth the information requested for each other affiliate.
1.
List the type of "intangible property" for which the expense is incurred and provide the intangible asset’s cost value as reported on the
affiliate’s balance sheet for the prior tax year or current tax year, or the fair market value, if available, and check the appropriate box
Type of Intangible Property
Asset Value (Cost/FMV)
COST
FMV
☐
☐
2.
Does the affiliate use the proceeds from the expense transaction: (check all that apply)
To pay dividends
To loan back to a member of the affiliated group
Directly in affiliate's business operations
To invest in public securities
Other: ________________________________
2a. If the affiliate loans the proceeds back to a member of the affiliated group, attach evidence showing that the loan is being or has been
repaid. Include the amount of interest earned annually.
3.
When the affiliate has to support, legally defend, or authorize use of "intangible property," does it use:
Its own employees
Employees of an affiliated group member
Contract labor
Outside professional legal counsel
Other: _______
3a. Provide a detailed explanation of how the affiliate supports, legally defends, and/or authorizes use of "intangible property."
4.
Attach the following information:
a) Complete copy of the affiliate’s pro forma federal income tax return for prior tax year or current tax year, if available.
b) To the extent known by the taxpayer, provide a list of the names and FEIN of other entities to which you are affiliated and subject to
tax in TN that are also paying, accruing, or incurring intangible expenses to the affiliate.
c) Description of the business activity of the affiliate to whom the expense is paid.
d) List of the location(s) where the principal business activities of the affiliate take place. Specify the type of activity by location, and
include the total number of full-time employees of affiliate.
e) If the affiliate to whom the expense is paid has less than ten (10) employees, provide detailed information concerning these
employee(s), including their names, titles, job descriptions, and work addresses. Describe key employees’ day-to-day activities and
disclose if they also work for others.
f) Detailed explanation of the means by which the intangible asset(s) were transferred to the affiliate, e.g., by the payment of cash, by
journal entry, etc. Provide a copy of the transfer document if applicable.
g) Detailed explanation of the method used to measure or determine the intangible expense, including schedules showing the calculation
of the amount. Include any relevant documents evidencing independent examinations, studies, and/or analyses upon which you rely.
h) Provide documentation showing actual payments of the expense. If the affiliate loans the proceeds back to the taxpayer, provide the
details regarding this loan.
i) Provide any other information that taxpayer deems relevant to demonstrate affiliate’s business purpose.
POWER OF ATTORNEY Check YES if this
I certify, under penalty of perjury, that the information provided in and with this application is true and correct to
taxpayer’s signature certifies that this tax
the best of my knowledge and understanding.
preparer has the authority to execute this form
on behalf of the taxpayer and is authorized to
_____________________________________________
___________________
______________
receive and inspect confidential tax information
Signature of Taxpayer, Officer or Representative
Title
Date
and to perform any and all acts relating to
☐ YES
respective tax matters.
_____________________________________________
___________________
______________
Tax Preparer’s Signature
Preparer’s PTIN
Date
INSTRUCTIONS FOR FORM IE-A
OFFICE USE ONLY ►
RV-F1406601
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