Purchase Price Allocations: Tax and Contractual Aspects

• Published in: The Tax lawyer Vol. 78; no. 3; pp. 317 - 359
• Main Authors: Soled, Jay A, Goodman, Leonard, Kornstein, Alan, Gallagher, Daniela C
• Format: Journal Article
• Language: English
• Published: Washington American Bar Association 01.04.2025
• Subjects: Acquisitions & mergers; Agreements; Asset acquisitions; Capital losses; Disregarded entities; Equity; Equity stake; Income taxes; Partnership interest; Provisions; Reporting requirements; Tax legislation; Tax rates
• ISSN: 0040-005X; 2329-6089

It is commonly understood among tax practitioners that, even though not required by the Code, an agreement for the purchase and sale of business assets ideally should allocate the purchase price to the different categories of assets being conveyed or, alternatively, provide a methodology that achiev...