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Re: boston745 post# 9531

Thursday, 07/27/2017 11:47:10 AM

Thursday, July 27, 2017 11:47:10 AM

Post# of 41781
The term “milestone” means an event occurring in the course of a covered transaction (whether the transaction is ultimately completed or not), provided that the event is (i) the execution of an agreement described in § 1.263(a)-5(e)(1)(i) (i.e., a letter of intent, exclusivity agreement or similar written communication (other than a confidentiality agreement)), (ii) an event described in § 1.263(a)-5(e)(1)(ii) (the authorization or approval of a transaction (as tentatively agreed to by representatives of the acquirer and the target) by the taxpayer's board of directors (or committee of the board of directors)), or (iii) some other specified event (other than the successful closing of the transaction), provided that the event does not occur prior to the first occurrence of an event described in § 1.263(a)-5(e)(1)(i) or (ii).

https://www.irs.gov/businesses/corporations/examination-of-milestone-payments-in-the-acquisition-of-businesses

milestone payment via LOI & IRS tax code...ding ding ding.
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