IRS directive on milestone payments leaves some issues unresolved

May 2013


The IRS Large Business and International Division (LB&I) recently issued a memorandum directing LB&I staff to not challenge the treatment of certain ‘eligible milestone payments’ paid in the course of a covered transaction in which the taxpayer also incurs a success-based fee and certain other requirements are met (the directive).  However, the directive may not provide the simplification and certainty that taxpayers desire.

Return to Tax research and insights 
Washington National Tax Services newsletter archive

Contact us

Pam Olson
US Deputy Tax Leader & Washington National Tax Services Leader
Tel: +1 (202) 414 1401

Follow us