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IRS PLR: Success-Based Fees Safe Harbor Election Extension Granted (IRC §263)

May 29, 2020, 5:00 AM

In the wake of a merger transaction, a company in the business of providing content and software tailored for educational use received extra time to file a statement pursuant to Revenue Procedure 2011-29 for its election of the safe harbor for success-based fees paid to two advising firms. According to the representation, a tax consultant recommended that Taxpayer make the election and attach a statement but didn’t provide such statement, and another tax professional prepared Taxpayer’s return, which was timely filed — but the statement wasn’t attached. The IRS in its analysis said Taxpayer’s return was in compliance with...

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