Thought-provokinganalysis and opinion on federal tax issues

Monthly Archives: September 2020

AICPA Comments On IRS Negative Tax Capital Reporting

September 19, 2020

by Monte A. Jackel

The AICPA recently released a comment letter it sent to the IRS on the tax basis negative capital proposed reporting regime.https://aboutbtax.com/TbQ. 1. The purpose of this reporting regime, as I understand it, is to ensure that a partner reports the recapture of the excess of his share of debt over his tax basis when a […]

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New S Corporation Case And The Check-The-Box Regulatons

by Monte A. Jackel

This case came out today. https://www.ustaxcourt.gov/USTCInOp2/OpinionViewer.aspx?ID=12322.  1. It deals with whether a controlling person of a Kentucky not for profit corporation was an S corporation shareholder.  2. I do not disagree with the holding of the court, which seems very apparent; beneficial ownership, a proprietary interest, is necessary to be a shareholder. 3. However, the mode […]

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Carried Interests Three Part Article

September 5, 2020

by Monte A. Jackel

I am attaching the three part article I published in Tax Notes Today Federal, Tax Analysts, Fairfax, VA, on carried interests and the new section 1061 proposed regulations. https://jackeltaxlaw.com/wp-content/uploads/2020/09/Jackel-Carried-Interests-Combined-Article.pdf. I thought it would be of interest.

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