A completed business transaction is one where the tax treatment of that transaction or item can no longer be affected by events that have not yet occurred. This means that all relevant actions and conditions that could influence the tax consequences of the transaction have been finalized, and no future events can alter its tax treatment.
The IRS FAQ clarifies that the Compliance Assurance Process (CAP) Program does not change existing procedures for issuing determinations regarding prospective transactions or incomplete transactions. It also emphasizes that CAP teams should not discuss the tax implications of any transaction or item until the tax treatment of that transaction or item can no longer be affected by events that have not yet occurred.
Sources:
TAM 9704002
CCA 200102049
§ 1.6050I-1. Returns relating to cash in excess of $10,000 received in a trade or business.
CCA 200247035
CCA 200936028
