Rev. Proc. 2011-29

IRS Declines To Extend Time To Make Late Success-Based Fee Elections

Recently, the IRS Office of Chief Counsel held, in a private letter ruling, that it could not grant a taxpayer’s request for an extension of time to file a safe harbor election under Rev. Proc. 2011-29. This election is related to the treatment of success-based fees incurred in the process of pursuing certain transactions. Under the safe harbor election described in Rev. Proc. 2011-29, the election must be made on an original tax return. The election applies to covered transactions under Treas. Reg. Sec. 1.263(a)-5(e)(3).

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