Category Archives: Partners and Partnerships
Link to My Articles on SSRN
February 6, 2024
by Monte A. Jackel
See this link to SSRN which has my research papers on a variety of tax subjects.
Read MoreSomeone Is Impersonating Me On Facebook
March 19, 2023
by Monte A. Jackel
I no longer have an account at Facebook but someone is impersonating me. That is not me. Ignore it. I reported it to Facebook.
Read MoreSome Recent Developments On My Medium Platform
February 26, 2023
by Monte A. Jackel
I have recently posted some additional items on my Medium platform. See https://medium.com/jackeltaxlaw.
Read MoreInaugural Post On SSRN
February 17, 2023
by Monte A. Jackel
This is a link to my first post on SSRN. It is a compendium of articles and letters in Tax Notes that I have written in the past year or so relating to partnership tax reform. https://ssrn.com/author=5717022
Read MoreUpdated Partnership Aggregate-Entity Outline
January 31, 2023
by Monte A. Jackel
I posted an outline of partnership aggregate-entity authorities on the Medium.com platform here, https://lnkd.in/eF35i-fQ.
Read MoreLatest Post In Medium On UPCs and Abuse
January 23, 2023
by Monte A. Jackel
See my latest at medium.com. https://medium.com/jackeltaxlaw/the-partnership-anti-abuse-rule-and-upreit-structures-revisited-e2643e19e649
Read MorePartnership Regulation Examples Not Supported by Text
January 16, 2023
by Monte A. Jackel
I recently posted this on my Medium.com platform.
Read MoreIt Is Time To First Reconsider And Then Enact Into Law Senator Wyden’s Partnership Tax Reforms
January 13, 2023
by Monte A. Jackel
The taxation of partnerships and partners, or more appropriately, the lack thereof, has been in the news lately. (See “Wyden Statement on Ways & Means Investigation of Presidential Audit Program,” Dec. 21, 2022.) As Senator Wyden recently stated in his reported comments on the House report on presidential audits: “Donald Trump’s tax returns exemplify the shortcomings of […]
Read MoreSome Recent Posts of Mine at Medium.com
January 4, 2023
by Monte A. Jackel
FYI. See http://jackeltaxlaw.medium.com. The posts relate to Trump’s taxes and conservation easements. https://jackeltaxlaw.com/wp-content/uploads/2023/01/The-Key-Lesson-To-Be-Learned-From-Trump.pdf
Read MoreINAUGURAL ARTICLE AT MEDIUM.COM
December 20, 2022
by Monte A. Jackel
To read my inaugural article on the medium.com platform, see https://medium.com/jackeltaxlaw/conservation-easement-restriction-in-omnibus-soon-to-become-law-5db3dbab40fd.
Read MoreUpdate To Status
December 18, 2022
by Monte A. Jackel
This is to note that I am no longer of counsel to Leo Berwick LLP. I continue as the principal of Jackel Tax Law, focused on federal tax law consulting, tax law commentary and tax policy analysis. You can find articles and other writings of mine at either Tax Notes https://www.taxnotes.com/, LinkedIn https://www.linkedin.com/in/monte-a-jackel-18921024/recent-activity/, at medium.com […]
Read MoreI Am Joining Leo Berwick As Of Counsel
January 10, 2021
by Monte A. Jackel
I am pleased to announce that I will be joining Leo Berwick https://leoberwick.com/ as Of Counsel. https://jackeltaxlaw.com/wp-content/uploads/2020/12/Leo-Berwick-LINKEDIN-Banner.jpg. This association will allow me to continue to comment and publish on tax matters while teaming with other seasoned tax professionals to advise on complex transactions. Leo Berwick is a new firm made up of ex-Big 4 and […]
Read MoreFrom Procedurally Taxing Blog On Phantom Regulations
December 30, 2020
by Monte A. Jackel
This was posted yesterday on the Procedurally Taxing blog. https://procedurallytaxing.com/. The text is reproduced below. The substance of this blog will be published as a letter to the editor of Tax Notes, Tax Analysts, Fairfax VA, on this coming Saturday/Monday. Introduction In recently finalized small business accounting regulations (T.D. 9942, Dec. 23, 2020), the IRS and Treasury […]
Read MoreLetter to the Editor of Tax Notes on Partnerships and Proposed Conservation Easement Bill
December 13, 2020
by Monte A. Jackel
I published this on December 14, 2020 in Tax Notes https://www.taxnotes.com/tax-notes-federal/partnerships/conservation-easement-bill-does-not-jibe-partnerships/2020/12/14/2d99w on the proposed charitable easement bill limiting the section 170 deduction for partnerships. It is reproduced below. “I write this letter in response to Kristen A. Parillo’s news story titled “House Easement Abuse Bill Contains Break for Historic Buildings” (Dec. 8, 2020). The story summarizes the […]
Read MoreA Link To My Articles At Tax Analysts
November 20, 2020
by Monte A. Jackel
I am attaching a link to my articles and letters at Tax Analysts (which is behind a paywall). https://jackeltaxlaw.com/wp-content/uploads/2020/10/Jackel_Monte_IN_450x255.png Thought it would be of interest.
Read MorePotential Regulatory Projects For New Administration
November 16, 2020
by Monte A. Jackel
I thought the attached would be of interest. https://jackeltaxlaw.com/wp-content/uploads/2020/11/Potential-Regulatory-Projects.docx
Read MoreENTITY LEVEL SALT TAXES ONCE AGAIN
November 12, 2020
by Monte A. Jackel
Notice 2020-75, issued a few days ago, held that the so-called SALT workarounds using state laws that allow the partners to cause the partnership entity to incur an entity level income tax with a credit at the partner level, are true entity level taxes and that the SALT limitation of section 164 as amended by […]
Read MoreA Principal Purpose Regs Over The Past Few Decades
October 26, 2020
by Monte A. Jackel
I am attaching a short write-up on the “a principal purpose” anti-abuse regulations generally. I thought this would be of interest. https://jackeltaxlaw.com/wp-content/uploads/2020/10/A-Principal-Purpose.docx.
Read MoreA Thank You To Tax Analysts and to Eric Sloan
October 9, 2020
by Monte A. Jackel
I wanted to thank Tax Analysts for both helping to promote me and for its assistance and support over the years. I also wanted to personally thank Eric Sloan of Gibson Dunn for the quote he gave them. Eric is a true professional. Please see this link for a promotional ad by Tax Analysts for […]
Read MoreProcedurally Taxing Blog Post By Me On Guaranteed Payments and the Validity of Tax Regulations
by Monte A. Jackel
This blog post from the Procedurally Taxing blog site discusses the guaranteed payment as interest issue in the context of how to challenge the validity of tax regulations. I thought it would be of interest. https://procedurallytaxing.com/consistency-and-the-validity-of-regulations/
Read MoreInconsistent Treatment Of Guaranteed Payments As Interest Expense
October 2, 2020
by Monte A. Jackel
Guaranteed payments resemble interest expense under section 163 but those payments are not, as a technical matter, interest on actual indebtedness. Recent IRS regulations have treated guaranteed payments inconsistently. Below is the substance of a letter to the editor that I will be publishing in Tax Notes next Monday. Text Of Substance Of Letter: How […]
Read MoreAICPA Comments On IRS Negative Tax Capital Reporting
September 19, 2020
by Monte A. Jackel
The AICPA recently released a comment letter it sent to the IRS on the tax basis negative capital proposed reporting regime.https://aboutbtax.com/TbQ. 1. The purpose of this reporting regime, as I understand it, is to ensure that a partner reports the recapture of the excess of his share of debt over his tax basis when a […]
Read MoreNew S Corporation Case And The Check-The-Box Regulations
by Monte A. Jackel
This case came out today. 1. It deals with whether a controlling person of a Kentucky not for profit corporation was an S corporation shareholder. 2. I do not disagree with the holding of the court, which seems very apparent; beneficial ownership, a proprietary interest, is necessary to be a shareholder. 3. However, the mode […]
Read MoreCarried Interests Three Part Article
September 5, 2020
by Monte A. Jackel
I am attaching the three part article I published in Tax Notes Today Federal, Tax Analysts, Fairfax, VA, on carried interests and the new section 1061 proposed regulations. https://jackeltaxlaw.com/wp-content/uploads/2020/09/Jackel-Carried-Interests-Combined-Article.pdf. It can also be found at this link from a recent LinkedIn post. https://www.linkedin.com/feed/update/urn:li:activity:6717385115091169280/. I thought it would be of interest.
Read MorePart Two Of Carried Interests Article In Tax Notes
August 22, 2020
by Monte A. Jackel
Part two of my three part article on the section 1061 proposed regulations in Tax Notes is out today. Here is a link. Tax Notes Article . It is behind Tax Analysts’ paywall. I thought it would be of interest.
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