Category Archives: International Taxation
Partnership Aspects of Final FDII Regulations
July 12, 2020
by Monte A. Jackel
I put together this brief outline with highlights and the pertinent provisions of the final FDII regulations as they relate to partnerships and partners. https://jackeltaxlaw.com/wp-content/uploads/2020/07/Proposed-250-regs.docx. Thought it would be of interest. The highlights of these regulations as they relate to partnerships and partners follow. With respect to partnerships and partners, the inclusion rule refers to […]
Read MoreIRS 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 […]
Read MoreThe 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/
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 More