The IRS Large Business and International (LB&I) division today publicly released a “practice unit”—part of a series of IRS examiner “job aides” and training materials intended to describe for IRS agents leading practices about tax concepts in general and specific types of transactions.
The title of the practice unit is: Allocation of success-based fees in a covered transaction
This practice unit explains:
The practice unit discusses a process for IRS examiners to follow in reviewing the allocation of success-based fees paid in a covered transaction between facilitative and non-facilitative activities when the safe harbor allocation is not elected.
Read the practice unit on the IRS practice unit webpage (posting date of June 13, 2019).
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