Washington — The Treasury Department and the Internal Revenue Service say that they will propose regulations regarding the treatment of amounts that facilitate certain tax-free and taxable transactions and other restructurings, and that are required to be capitalized under Code Section 263.

In Notice 2004-18, the Treasury requests comments regarding the appropriate treatment of certain transaction costs that are required to be capitalized, including whether such costs should be treated as giving rise to a new asset with an amortizable basis.

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