Transaction with contractual protection definition
Transaction with contractual protection means a transaction for which the taxpayer or a related party (as described in I.R.C. § 267(b) or I.R.C. § 707(b)) has the right to a full or partial refund of fees if all or part of the intended tax consequences from the transaction are not sustained. A transaction with contractual protection also is a transaction for which fees are contingent on the taxpayer's realization of tax benefits from the transaction.