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IRS PLR: Success-Based Fees Safe Harbor Election Extension Granted (IRC §263)

June 18, 2021, 5:00 AM

A seller of kitchenware and other home products, in the wake of two successive merger transactions, received extra time to file mandatory statements pursuant for its election of the safe harbor for success-based fees paid to an advisor. Amid a change in tax preparation firms, although the statement was not attached to Taxpayer’s timely filed return, Taxpayer capitalized the transaction costs in accordance with tax code Section 263, Treasury Regulations Section 1.263(a)-2 and Section 1.263(a)-5, and Revenue Procedure 2011-29, according to the representation. [PLR 202124005]

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