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Explainer: What are ‘covered, suspicious transactions’

As the impeachment proceedings against Vice President Sara Duterte resumed on Wednesday, April 22, lawmakers put financial review in focus, citing Anti-Money Laundering Council (AMLC) reports on ...
JD Supra

Success-Based Fees: Elect the Safe Harbor or Document Thoroughly

When taxpayers pay fees contingent on the successful closing of certain “covered transactions,” including, for example, taxable acquisitions of assets that constitute a trade or business, such ...
JD Supra

IRS Rules That A Partially Tax-Free Transaction Qualifies As ‘Covered Transaction’ For Purposes Of The Transaction Cost Regulations

The Internal Revenue Service (the Service) recently released Priv. Ltr. Rul. 2013-19-009, 1 which interprets the transaction cost regulations of Treas. Reg. §1.263(a)-5. Under these rules, transaction ...