Tax Accounting in Mergers and Acquisitions, 2008

Highlights Of The 2008 Edition Include The Following:

• A global example that sets forth issues commonly encountered in a transaction.
• A discussion of the potential impact of § 267 on the tax treatment of the seller where contingent liabilities are assumed.
• The impact of FIN 48 and § 6694 on the deductibility of success-based fees paid in connection with a transaction.
• An analysis of the dichotomy resulting from the proposed regulations regarding tangible property on the treatment of transaction costs incurred in connection with business expansion effected internally (i.e., organic business expansions) and business expansions effected through acquisitions.
• A discussion of special issues relating to the treatment of a target’s transaction costs.
• A discussion of the impact of § 162(k) on the treatment of transaction costs.