Thought-provokinganalysis and opinion on federal tax issues

Monthly Archives: April 2020

IRS Issues PTP Look-through Ruling That Lacks Authority

April 21, 2020

by Monte A. Jackel

I wrote a letter to the editor of Tax Notes relating to an issue of the pass-through treatment of PTPs when applying the investment company rules of section 351(e) and 721(b). https://www.taxnotes.com/tax-notes-today-federal/partnerships-and-other-passthrough-entities/letter-ruling-ptp-look-through-illegal/2020/04/21/2cfn8. I also posted a comment to that letter in LinkedIn and Twitter. https://www.linkedin.com/feed/update/urn:li:activity:6658337228848156672/ and https://twitter.com/jackeltaxlaw/status/1252571602698620928. Thoughtful feedback to either me or the government […]

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Deduction of Payroll Costs under PPP of the CARES Act

April 13, 2020

by Monte A. Jackel

The attached story from the Wall Street Journal, which quotes me as well as several others, explains the condundrum. https://secureservercdn.net/198.71.233.96/wk8.36e.myftpupload.com/wp-content/uploads/2020/04/Multibillion-Dollar-Tax-Muddle-Hovers-Behind-Small-Business-Loan-Program-WSJ.pdf

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