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Ellen McElroy

Ellen McElroy

Pepper Hamilton LLP


Latest Publications

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New Directive Correctly Resolves Use Of Transaction Cost Safe Harbor For Milestone Payments – Questions Nonetheless Linger

A new directive specifies that Large Business & International (LB&I) examiners should not challenge a taxpayer’s treatment of eligible milestone payments when success-based fees are incurred, provided a safe harbor election...more

5/8/2013 - IRS Milestone Payments Safe Harbors Transaction Costs

IRS ‘Repairs’ The Examination Of Tangible Property Regulation Issues

In March, the Internal Revenue Service published an IRS Large Business & International (LB&I) Directive (the Directive), which updates an earlier directive to field agents addressing the examination of capitalization and...more

5/7/2013 - Future Tax Treatment IRS Proposed Regulation Tangible Property

Tax Issues Stirred Up by Hurricane Sandy

In late October, Hurricane Sandy caused significant damage to many businesses throughout the Northeastern United States. In the past, business taxpayers experiencing similar storm damage would have focused primarily on the...more

12/3/2012 - Hurricane Sandy IRS Property Damage

IRS Defers Effective Date for Repair Regulations

In Notice 2012-73,1 the IRS announced that its regulations will be amended to delay the effective date of the 2011 temporary tangible property regulations (T.D. 9564) (the 2011 Regulations), which were to apply to tax years...more

12/3/2012 - IRS

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