Thought-provokinganalysis and opinion on federal tax issues

Category Archives: International Taxation

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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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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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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