Taxpayers typically incur significant transaction costs when undergoing a transaction involving a restructuring, acquisition, disposition, sale of assets, or sale of stock. The default rule under section 263 is that all...more
The treatment of transaction costs in the context of a transaction involving a partnership that is either the acquiring entity or the target entity raises unique issues....more
California requires taxpayers that have income within and outside the state to "apportion" their overall income between the two categories based upon certain factors and rules for determining their California tax liability....more