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Article: Don't overlook the credit for tax on prior transfers.
- Article from:
- The Tax Adviser
- Article date:
- May 1, 1997
- Author:
CopyrightCOPYRIGHT 1997 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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However, what is surprising is that the proposed regulations take the unprecedented view that a covenant not to compete entered into contemporaneously with a stock redemption is entered into "in connection with" the redemption for purposes of Sec. 162(k), which disallows a deduction "for any amount paid or incurred by a corporation in connection with the reacquisition of its stock...." In addition, Prop. Regs. Sec. 1.197-2(a)(4) states that "Section 197 does not apply to any amount paid or incurred for a section 197 intangible if a deduction for the amount would be disallowed under any provision of the Internal Revenue Code other than section 263. (See, for example, ...
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