Thought-provokinganalysis and opinion on federal tax issues

Dec
11

Tax Court Worthless Partnership Interest Loss Case Fails to Address Several Key Issues

December 11, 2019 | by Monte A. Jackel

In MCM Management, the Tax Court, in a memorandum opinion, held that a partnership interest was worthless and generated an ordinary loss based on the facts of the case. Some key takeaways from the case follow: There is no discussion in the case of cancellation of indebtedness income. Since the court held that there was […]

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Dec
09

Guaranteed Payments On Capital As Interest Expense

December 9, 2019 | by Monte A. Jackel

The attached outline discusses this https://jackeltaxlaw.com/wp-content/uploads/2019/12/COMMENTARY-ON-INTERACTION-OF-THE-TERM.docxissue.

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Dec
05

Highlights of Recent Foreign Tax Credit Regs and Partnerships

December 5, 2019 | by Monte A. Jackel

The recently proposed and final foreign tax credit regulations issued December 2 of this year provides the following key points relating to partnerships and partners. This is a brief summary only to highlight these changes. Further study is required. The final regulations finalize what are known as “downstream loans”, which are loans by partners to […]

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Nov
27

Sun Capital Case Rejects Joint Economics And Favors Separate Formalities In Determining Whether A Partnership In Fact Exists

November 27, 2019 | by Monte A. Jackel

The recent Sun Capital case in the First Circuit rejected the holding of the District Court below that two separate entities had formed a deemed partnership in fact due to their joint objectives, cooperation and sharing in joint profits and losses´┐╝. Rather, the First Circuit focused more heavily on the separateness of the two entities […]

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Nov
01

My Revised CV

November 1, 2019 | by Monte A. Jackel

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Oct
31

Partnership FAQs Inappropriate

October 31, 2019 | by Monte A. Jackel

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Oct
16

Cryptocurrency Guidance Defective

October 16, 2019 | by Monte A. Jackel

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