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Tax Allocation Agreements Internal Revenue Service

Update on Transaction Costs - 'Origin of the Claim' Analysis Will Decide Tax Allocations - Tax Update Volume 2017, Issue 3

by Pepper Hamilton LLP on

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

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

by Goulston & Storrs PC on

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs. ...more

Status Update on Targeted Allocation Regulations

I’m at the ABA Tax conference this week and one of this morning’s first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries,...more

IRS Slams Profits Interests In Lieu of Management Fees and More

by Goulston & Storrs PC on

The IRS issued the much anticipated proposed regulations that severely curtail the practice of a fund manager waiving management fees in exchange for a share of future partnership profits. In essence the regulations tighten...more

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