Hazards Ahead: The IRS’s Coordinated Issue Paper on Cost Sharing Buy-In Payments

Tax Management Memorandum
In this article, Rocco Femia and David Blair review the background to the buy-in issue and new positions from the Coordinated Issue Paper (CIP) that the IRS plans to use in challenging buy-in payments, then identifies several potential hazards for the IRS as it moves to apply the CIP to current buy-in disputes.
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