Monthly Archives: October 2020
A Principal Purpose Regs Over The Past Few Decades
October 26, 2020
by Monte A. Jackel
I am attaching a short write-up on the “a principal purpose” anti-abuse regulations generally. I thought this would be of interest. https://jackeltaxlaw.com/wp-content/uploads/2020/10/A-Principal-Purpose.docx.
Read MoreA Thank You To Tax Analysts and to Eric Sloan
October 9, 2020
by Monte A. Jackel
I wanted to thank Tax Analysts for both helping to promote me and for its assistance and support over the years. I also wanted to personally thank Eric Sloan of Gibson Dunn for the quote he gave them. Eric is a true professional. Please see this link for a promotional ad by Tax Analysts for […]
Read MoreProcedurally Taxing Blog Post By Me On Guaranteed Payments and the Validity of Tax Regulations
by Monte A. Jackel
This blog post from the Procedurally Taxing blog site discusses the guaranteed payment as interest issue in the context of how to challenge the validity of tax regulations. I thought it would be of interest. https://procedurallytaxing.com/consistency-and-the-validity-of-regulations/
Read MoreInconsistent Treatment Of Guaranteed Payments As Interest Expense
October 2, 2020
by Monte A. Jackel
Guaranteed payments resemble interest expense under section 163 but those payments are not, as a technical matter, interest on actual indebtedness. Recent IRS regulations have treated guaranteed payments inconsistently. Below is the substance of a letter to the editor that I will be publishing in Tax Notes next Monday. Text Of Substance Of Letter: How […]
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