Thought-provokinganalysis and opinion on federal tax issues

Category Archives: Partners and Partnerships

Link to My Posts on Tax Law & Policy Perspectives

February 6, 2024

by Monte A. Jackel

This is a link to my posts on the Tax Law & Policy Perspectives blog.

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Link to My Articles on SSRN

by Monte A. Jackel

See this link to SSRN which has my research papers on a variety of tax subjects.

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Link to My Posts on Medium.com

May 8, 2023

by Monte A. Jackel

This is a link to all of my posts to date at https://jackeltaxlaw.medium.com/.

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Someone 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.

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Some 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.

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Inaugural 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

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Updated 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.

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Latest 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

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Partnership Regulation Examples Not Supported by Text

January 16, 2023

by Monte A. Jackel

I recently posted this on my Medium.com platform.

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It 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 […]

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Some 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

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INAUGURAL 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.

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Update 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 […]

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I 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 […]

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From 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 […]

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Letter 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 […]

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A 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.

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Potential 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

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ENTITY 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 […]

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A 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.

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A 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 […]

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Procedurally 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/

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Inconsistent 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 […]

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AICPA 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 […]

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New 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 […]

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