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FROM THE OFFICE OF PUBLIC AFFAIRS
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The Treasury Department and IRS issued a notice today announcing their intention to propose regulations regarding the treatment of amounts that facilitate certain tax-free and taxable transactions and other restructurings, and that are required to be capitalized under section 263. The notice requests comments regarding the appropriate treatment of certain transaction costs that are required to be capitalized, including whether such costs should be treated as giving rise to a new asset the basis of which is amortizable.
“The proper treatment of amounts incurred to facilitate certain transactions has been the subject of disputes between taxpayers and the IRS in recent years,” stated Acting Treasury Assistant Secretary for Tax Policy Greg Jenner. “This notice is the first step toward providing clear and administrable rules.”
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