Industry Issue Resolution Pilot Program under Notice 2000-65
Financial Services Issues Contents | Introduction | I | II | III Final Comment We would be remiss if we did not include a comment on what we believe is the most significant tax controversy currently facing the banking industry - the treatment of loan origination costs. We view the recent decision in the case of PNC Bancorp, Inc. v. Commissioner, 8 as the correct interpretation of the law. Based on our conversations with IRS officials, it appears that the Service may be close to issuing guidance on this issue, which we presume would be consistent with the Third Circuit decision. If so, then the treatment of loan origination may not be one that needs to be resolved under the industry issue resolution pilot program. If our assessment is incorrect, however, and if the Service decides to address loan origination costs under the pilot program, we would welcome that action. Contents | Introduction | I | II | III | 
