Monthly Archives: December 2019
Passthroughs and Special Industries Must Spin Off Partnerships As A Separate Division
December 27, 2019
by Monte A. Jackel
I recently read a news story in the tax press about recommended changes to the IRS as part of the mandated report due next October under the Taxpayer First Act, P.L. 116-25. The act mandates a report to Congress relating to potential reorganization changes to the IRS. Although this act is directed at the Internal […]
Read MoreBrief Summary Of Ozone Final Regulations Highlights For Partnerships And Partners
December 22, 2019
by Monte A. Jackel
Read MoreTax Court Worthless Partnership Interest Loss Case Fails to Address Several Key Issues
December 11, 2019
by Monte A. Jackel
In MCM Management, the Tax Court, in a memorandum opinion, held that a partnership interest was worthless and generated an ordinary loss based on the facts of the case. Some key takeaways from the case follow: There is no discussion in the case of cancellation of indebtedness income. Since the court held that there was […]
Read MoreGuaranteed Payments On Capital As Interest Expense
December 9, 2019
by Monte A. Jackel
The attached outline discusses this https://jackeltaxlaw.com/wp-content/uploads/2019/12/COMMENTARY-ON-INTERACTION-OF-THE-TERM.docxissue.
Read MoreHighlights of Recent Foreign Tax Credit Regs and Partnerships
December 5, 2019
by Monte A. Jackel
The recently proposed and final foreign tax credit regulations issued December 2 of this year provides the following key points relating to partnerships and partners. This is a brief summary only to highlight these changes. Further study is required. The final regulations finalize what are known as “downstream loans”, which are loans by partners to […]
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