Transcription of Part III
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Part III
part III Administrative, Procedural, and Miscellaneous 26 CFR : Examination of returns and claims for refund, credit or abatement; determination of correct tax liability. (Also part I, 263(a), (a)-5) Rev. Proc. 2011-29 SECTION 1. PURPOSE This revenue procedure provides a safe harbor election for allocating success-based fees paid in business acquisitions or reorganizations described in (a)-5(e)(3) of the Income Tax Regulations. In lieu of maintaining the documentation required by (a)-5(f), this safe harbor permits electing taxpayers to treat 70 percent of the success-based fee as an amount that does not facilitate the transaction. The remaining portion of the fee must be capitalized as an amount that facilitates the transaction.
Part III Administrative, Procedural, and Miscellaneous 26 CFR 601.105: Examination of returns and claims for refund, credit or abatement; determination of correct tax liability.
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