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Tax Allocation Agreements › Internal Revenue Service › Transaction Costs

Troutman Pepper

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

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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

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