In April 2019, the IRS’s Large Business and International Division (LB&I) issued an LB&I Transaction Unit (LTU) that described potential positions a taxpayer may take to recover previously capitalized transaction costs....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
The tax treatment of costs incurred in a transaction can represent a significant deduction for the taxpayers involved. Even in the case of a corporation that is now taxed at the corporate rate of 21 percent, the deduction for...more
While the Internal Revenue Service (IRS) has continued to issue guidance addressing the ability to deduct transaction costs, the doctrine of "Origin of the Claim" (OOC) developed over 50-plus years of case law is still the...more