US IRS rules target’s capitalized transaction costs do not create a separate and distinct intangible asset
In technical advice memorandum 202004010 (the TAM), the United States (US) Internal Revenue Service (IRS or Service) ruled professional and administrative fees paid by a Target corporation in connection with the acquisition of its stock by Taxpayer did not create a separate and distinct intangible asset and were not deductible as a loss under Internal Revenue Code1 Section 165 by Target upon …
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