Thought-provokinganalysis and opinion on federal tax issues

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 […]

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Brief Summary Of Ozone Final Regulations Highlights For Partnerships And Partners

December 22, 2019

by Monte A. Jackel

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Tax 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 […]

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Guaranteed Payments On Capital As Interest Expense

December 9, 2019

by Monte A. Jackel

The attached outline discusses this https://secureservercdn.net/198.71.233.96/wk8.36e.myftpupload.com/wp-content/uploads/2019/12/COMMENTARY-ON-INTERACTION-OF-THE-TERM.docxissue.

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Highlights 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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