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U.S. IRS Releases Practice Unit on Transaction Costs in a Corporate Separation

13 May 2019

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Approved Changes

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United States

The U.S. IRS has released an international practice unit on Transaction Costs in a Corporate Separation. The practice unit discusses the treatment of transaction costs when a taxpayer engages in a corporate separation of a controlled corporation, such as a spin-off, split-off, or split-up, including: Costs that facilitate the separation transaction; Facilitative costs the distributing corporation capitalized when it acquired the controlled corporation's stock in a tax-free transaction; and Facilitative costs the controlled corporation capitalized when the distributing corporation acquired its stock. International practice units are developed by the Large Business and International Division of the IRS to provide staff...