U.S. IRS Releases Practice Unit on Transaction Costs in a Corporate Separation

The U.S. IRS has released an international practice unit on Transaction Costs in a Corporate Separation. The practice unit discusses the treatment of transaction costs when a taxpayer engages in a corporate separation of a controlled corporation, such as a spin-off, split-off, or split-up, including:

• Costs that facilitate the separation transaction;
• Facilitative costs the distributing corporation capitalized when it acquired the controlled corporation's stock in a tax-free transaction; an…