New IRS Guidance Offers Insight Regarding Covered Transactions Under the Transaction Cost Regulations
By EsqSocial Corporation 01/04/14
When the IRS released the transaction cost regulations of Treas. Reg. 1.263(a)-5, a new term was created: “covered transaction.” Unlike the treatment of a covered transaction in a tax shelter context, which is generally unfavorable, the transaction...
By: Pepper Hamilton LLP