This recent ruling by the IRS is significant for what it does not say. It does not say much of anything. It is a “significant issue” ruling, which is a type of limited ruling issued by the Corporate Division of Chief...more
When the IRS released the transaction cost regulations of Treas. Reg. 1.263(a)-5, a new term was created: “covered transaction.” Unlike the treatment of a covered transaction in a tax shelter context, which is generally...more