Thought-provokinganalysis and opinion on federal tax issues

IRS Issues PTP Look-through Ruling That Lacks Authority

April 21, 2020

by Monte A. Jackel

I wrote a letter to the editor of Tax Notes relating to an issue of the pass-through treatment of PTPs when applying the investment company rules of section 351(e) and 721(b). I also posted a comment to that letter in LinkedIn and Twitter. and Thoughtful feedback to either me or the government would be welcome.