The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more
Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more
New regulations issued by Treasury under Section 336(e) permit certain stock acquisitions to be treated as asset purchases, allowing buyers access to stepped-up asset basis and corresponding depreciation and amortization...more