Thought-provokinganalysis and opinion on federal tax issues

Mar
26

Corona virus business tax provisions

March 26, 2020 | by Monte A. Jackel

The attached document provides some highlights of the business provisions contained in the Senate bill. https://jackeltaxlaw.com/wp-content/uploads/2020/03/Virus-business-tax-provisions.docx

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Mar
20

Some Recent Posts on LinkedIn

March 20, 2020 | by Monte A. Jackel

I have posted a number of comments on LinkedIn dealing with various current developments. They are located here. https://www.linkedin.com/in/monte-a-jackel-18921024/detail/recent-activity/

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Feb
21

At Risk Basis for Guarantees

February 21, 2020 | by Monte A. Jackel

I am attaching a write-up on a recent Tax Court case dealing with at risk basis under section 465 and guarantees. https://jackeltaxlaw.com/wp-content/uploads/2020/02/At-risk-Tax-Court-case.docx

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Feb
20

Tax Credit Partnerships Again

February 20, 2020 | by Monte A. Jackel

I am attaching a short write-up on the issue of whether an investor will be treated as a partner in a tax credit partnership. https://jackeltaxlaw.com/wp-content/uploads/2020/02/Tax-Credit-Guidance.docx

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Feb
16

Table of Contents to Prior Posts

February 16, 2020 | by Monte A. Jackel

Attached is a link to a document containing a list of all prior posts which have previously been posted on this website. If you would like a copy of something previously published, please let me know. https://jackeltaxlaw.com/wp-content/uploads/2020/02/Table-of-contents-for-web-posts-1.pdf

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Feb
15

IRS Corrects Attribution Example in Final 721(c) Regs

February 15, 2020 | by Monte A. Jackel

I recently published an article in Tax Notes discussing the final regulations under section 721(c). See link which is behind Tax Notes’ paywall. https://www.taxnotes.com/tax-notes-today-federal/transfer-pricing/complexity-and-confusion-cross-border-partnership-regs-finalized/2020/02/10/2c3xl?highlight=Jackel . In the article, I pointed out that the attribution example in the final regulation preamble was incorrect because there is no concept of indirect ownership through corporations in the final […]

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Feb
01

The Politics of Regulation Drafting

February 1, 2020 | by Monte A. Jackel

The attached is a re-print of an article I recently published in Tax Notes on the politics of regulation drafting. I thought this would be of interest. https://jackeltaxlaw.com/wp-content/uploads/2020/01/Jackel-01-20-2020.pdf

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Jan
17

The Effective Date of Section 721(c) Regs

January 17, 2020 | by Monte A. Jackel

I wrote a short note on the effective date of the section 721(c) regulations on LinkedIn. I am really not sure of the answer. See attached link. https://www.linkedin.com/in/monte-a-jackel-18921024/detail/recent-activity/shares/

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Jan
03

My LinkedIn Posts For Tax Notes Articles and Stories

January 3, 2020 | by Monte A. Jackel

I cannot post my comments to Tax Notes stories and articles here because the Tax Notes stories are behind a pay wall, for those subscribers only. But here is a link to my LinkedIn page where you can find posts of mine dealing with those stories and articles. https://www.linkedin.com/in/monte-a-jackel-18921024/detail/recent-activity/

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Dec
27

Passthroughs and Special Industries Must Spin Off Partnerships As A Separate Division

December 27, 2019 | by Monte A. Jackel

I recently read a news story in the tax press about recommended changes to the IRS as part of the mandated report due next October under the Taxpayer First Act, P.L. 116-25. The act mandates a report to Congress relating to potential reorganization changes to the IRS. Although this act is directed at the Internal […]

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Dec
22
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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