Thought-provokinganalysis and opinion on federal tax issues

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://secureservercdn.net/198.71.233.96/wk8.36e.myftpupload.com/wp-content/uploads/2020/10/A-Principal-Purpose.docx.

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A 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 […]

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Procedurally 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/

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Inconsistent 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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