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Asset Buyer’s Substance Over Form Argument Wins $3 Million Amortization Deduction

The IRS challenged the buyer’s $3 million amortization deduction in an asset acquisition based upon the structure chosen by the parties to the transaction. The tax court however, allowed the amortization deduction based upon the economic substance of the transaction.

Posted in amortization, form over substance, substance over form, Taxation Tagged with: ,

Chosen Merger Structure Accelerates over $2 million in Taxes for Seller

July 21, 2020 Introduction Selling a business usually generates significant tax consequences. However, a transaction can sometimes be structured to defer the payment of taxes. The deal The business owner held the KFC and Pizza Hut franchises in Russia through

Posted in boot, cash, form over substance, merger, substance over form, tax deferred reorganization Tagged with: ,

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