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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

Troutman Pepper 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

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