Brief Summary Of Ozone Final Regulations Highlights For Partnerships And Partners
December 22, 2019 | by Monte A. Jackel
Read MoreTax 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 […]
Read MoreGuaranteed 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.
Read MoreHighlights 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 […]
Read MoreSun 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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