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IRS Legal Memorandum Addresses Stock Options and Other Transaction-Related Deductions
Wilson Sonsini Goodrich & Rosati [Guidance Overview] Feb. 1, 2013 "On January 28, 2013, the [IRS] published a generic legal advice memorandum (GLAM), AM2012-10, addressing the timing under the consolidated return regulations of certain deductions that commonly arise in an acquisition, including compensation deductions attributable to amounts paid to cash out a target company's non-qualified stock options (NQOs) and stock appreciation rights (SARs) held by employees.... The GLAM is not binding legal authority, but is a significant statement of the IRS's position with respect to what can be a material issue in an acquisition. If the IRS is correct, option deductions and certain other deal-related deductions that cannot be allocated to the post-closing periods will be immediately useable only if the target is profitable, or possibly if it had been profitable in prior periods and can claim a refund." |
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