Gain insight into the tax treatment of transaction costs in commonly encountered business scenarios.
This topic will equip you with knowledge of the tax treatment of transaction costs in commonly encountered business scenarios. Using real world examples and case studies, this material will guide you through the general rule of capitalization under Section 263(a) focusing on due diligence costs, facilitative and nonfacilitative costs and covered transactions. The information and materials will examine asset and business transaction types and the effect of such on transactional cost tax treatment. Of note, this topic provides special attention to the effect of 2017's TCJA on transaction costs and reviews treatment of success-based fees in business transactions.
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Agenda
The General Rule of Capitalization
- Section 263(a)
- INDOPCO, Inc. v. Commissioner
Costs Subject to Capitalization
- Principles
- Origin of the Claim Doctrine
- Facilitative Costs - Reg. §§ 1.263(a)-5
Costs Not Subject to Capitalization
- Nonfacilitative Costs
When Costs Are Capitalized
- Accrual Method
- Cash Method
Impact of 2017 TCJA
- Expensing Under SEC. 168
Business/Transaction Costs
- IRS LB and I Process Unit (2018)
- Identifying Proper Legal Entity
- Facilitative Costs
- Covered Transactions
- Success-Based Fees
- Start-up Expenses
- Due Diligence Costs
- Business Acquisition Costs
- Partnership Considerations
- Reorganization Expenses
- Break-up Fees
Transaction Costs Incurred to Produce Intangible Property
- Capitalization Under Regulations
Real Estate Transaction Costs
IRS Audit Considerations
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on November 21, 2019.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Todd Denison
Phelps Dunbar LLP
- Partner with Phelps Dunbar LLP
- Represents individuals and business entities in the areas of business transactions and operations, partnership and corporate taxation, real and personal property transactions, trusts and estates (including sophisticated estate) planning, charitable organizations (formation and operations), employee stock ownership plans and other qualified retirement plans, captive insurance, international transactions and taxation, tax controversies with the IRS, and elder law
- Clients include a regional engineering firm, national advertising agency, regional construction firm, regional stone and interior design firm, and numerous family-owned businesses operating locally, regionally, and internationally
- Frequent speaker and has several publications
- Member of numerous professional and civic organizations
- Achieved the highest rating with Martindale-Hubbell Law Directory
- The Best Lawyers in America© (Woodward/White, Inc.), Business Organizations (including LLCs and Partnerships) in Mobile, 2019; Tax Law in Mobile, 2018-2019; Trusts and Estates in Mobile, 2018-2019
- LL.M. degree, New York University School of Law; J.D. degree, University of Montana School of Law; M.A. and B.A. degrees, University of Montana
- Can be contacted at 251-441-8206 or [email protected]
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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