Thought-provokinganalysis and opinion on federal tax issues

Monthly Archives: February 2020

At Risk Basis for Guarantees

February 21, 2020

by Monte A. Jackel

I am attaching a write-up on a recent Tax Court case dealing with at risk basis under section 465 and guarantees. https://secureservercdn.net/198.71.233.96/wk8.36e.myftpupload.com/wp-content/uploads/2020/02/At-risk-Tax-Court-case.docx

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Tax Credit Partnerships Again

February 20, 2020

by Monte A. Jackel

I am attaching a short write-up on the issue of whether an investor will be treated as a partner in a tax credit partnership. https://secureservercdn.net/198.71.233.96/wk8.36e.myftpupload.com/wp-content/uploads/2020/02/Tax-Credit-Guidance.docx

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Table of Contents to Prior Posts

February 16, 2020

by Monte A. Jackel

Attached is a link to a document containing a list of all prior posts which have previously been posted on this website. If you would like a copy of something previously published, please let me know. https://secureservercdn.net/198.71.233.96/wk8.36e.myftpupload.com/wp-content/uploads/2020/02/Table-of-contents-for-web-posts-1.pdf

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IRS Corrects Attribution Example in Final 721(c) Regs

February 15, 2020

by Monte A. Jackel

I recently published an article in Tax Notes discussing the final regulations under section 721(c). See link which is behind Tax Notes’ paywall. https://www.taxnotes.com/tax-notes-today-federal/transfer-pricing/complexity-and-confusion-cross-border-partnership-regs-finalized/2020/02/10/2c3xl?highlight=Jackel . In the article, I pointed out that the attribution example in the final regulation preamble was incorrect because there is no concept of indirect ownership through corporations in the final […]

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The Politics of Regulation Drafting

February 1, 2020

by Monte A. Jackel

The attached is a re-print of an article I recently published in Tax Notes on the politics of regulation drafting. I thought this would be of interest. https://secureservercdn.net/198.71.233.96/wk8.36e.myftpupload.com/wp-content/uploads/2020/01/Jackel-01-20-2020.pdf

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