HK® Bobby Pen & The Pen Pals® FED55C COMPRESSED Related Party Transactions

“Related Party” Transactions

This article focuses on “related party” transactions under Internal Revenue Code Section 267(a)(1) and Internal Revenue Code Section 1239(a). While there is some overlap, it should be noted that the specific scope of “related parties” for purposes of a “related party” transaction under Internal Revenue Code Section 1239(a) is different than the specific scope of “related parties” under Internal Revenue Code Section 267(a)(1).

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