Categories: Articles

IRS Creates Safe-Harbor for the Deduction of M&A Success Based Fees

The Internal Revenue Service has created a safe-harbor election under Revenue Procedure 2011-29 to allow taxpayers to allocate seventy percent (70%) of the success-based fees paid in business acquisitions or reorganization as a deduction against current ordinary income. If the election is made, the remaining thirty percent (30%) must be capitalized. This election can be made for success-based fees incurred in years ending on or after April 8, 2011. This Revenue Procedure clears up the uncertainty that has existed in how to allocate these fees.

Published by
ONeil Cannon

Recent Posts

Former O’Neil Cannon Attorneys Devoted to Public Service

A number of former O’Neil Cannon attorneys have devoted a substantial portion of their professional…

5 hours ago

College Athletics Are A-Changing

The transfer portal and NIL (name, image, and likeness) payments have recently significantly changed the…

1 week ago

Spring Cleaning for Your Business: Consider Your Document Retention Practices

Spring is the season for cleaning and organization—and it can also be a good time…

1 month ago

Wisconsin Incentivizes “Closing Credits” by Opening New Tax Credits for Filmmakers

A significant development to Wisconsin’s economic and cultural policy is now underway, as Governor Tony…

1 month ago

O’Neil Cannon Adds Four Shareholders

O’Neil Cannon is pleased to announce that Christina Ruud, Cate Heerey, Nancy Wilson, and Max…

2 months ago

O’Neil Cannon Welcomes Attorney Sabrina Dornan

O’Neil Cannon is pleased to announce that Sabrina Dornan has joined the firm. Dornan focuses…

2 months ago