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Monte A Jackel in Jackeltaxlaw

Jul 11, 2023

Potential Implications of Supreme Court Review in Moore Case

Based in part in a letter to the editor of Tax Notes on July 10, 2023.

On June 26, 2023, the U.S. Supreme Court granted certiorari in Moore,1 a case from the U.S. Court of Appeals for the Ninth…

Monte A Jackel in Jackeltaxlaw

May 4, 2023

Tax Court Clarifies What A Profits Interest Is

The U.S. Tax Court has held in ES NPA Holding, T.C. Memo 2023–55, that an interest in a partnership granted for services was a profits interest that was not taxable to the taxpayer under Revenue Procedure 93–27.

Monte A Jackel in Jackeltaxlaw

Jan 31, 2023

Partnership Aggregate-Entity Summary of Authorities

Updated Feb. 8, 2023

1. General Principle of Law

The general principle of law underlying aggregate or entity treatment of a partnership is set forth in the 1954 Conference Report on Section…

Monte A Jackel in Jackeltaxlaw

Dec 20, 2022

Conservation Easement Charitable Deduction Restriction In Omnibus Bill Becomes Law

Monte A. Jackel

December 30, 2022

(Updated from December 20, 23 and 29)

Monte A Jackel in Jackeltaxlaw

Jan 2, 2023

The Key Lesson To Be Learned From Trump’s Tax Returns: A Response To The NY Times

January 2, 2023

(Updated January 3 and 4, 2023)

The NY Times recently published an analysis relating to the key takeaways from Trump’s tax…

Monte A Jackel in Jackeltaxlaw

Jun 16, 2023

Some Brief Comments on the Section 6418 Transfer Credit Proposed Regulations

June 16, 2023

Updated June 19, 2023

Proposed regulations were filed with the Federal Register on June 14 under IRC section 6418. See REG-101610–23.

Monte A Jackel in Jackeltaxlaw

Feb 6, 2023

Auditing and Tax Do Not Play Well Together

Updated Feb. 8, 2023

Recent news reports have disclosed the accounting firm Ernst & Young’s (EY) purported plan to separate its consulting business from its global audit practice. (Mark Maurer and Jean Eaglesham, “Accounting Firm…

Monte A Jackel in Jackeltaxlaw

Jan 23, 2023

The Partnership Anti-abuse Rule and UpReit Structures Revisited

Taxpayers are straying outside the lines when it comes to so-called UP structures, whose name derives from the umbrella partnership real estate investment trust (UpReit), but can also involve C corporations (Up-Cs) and…

Monte A Jackel in Jackeltaxlaw

Feb 11, 2023

Federal Income Tax Treatment of The Sale of A Partnership Interest By A Nonresident Of the U.S.

In Rawat (Rawat v. Commissioner, T.C. Memo 2023–14, Tax Court Judge David Gustafson, who also authored the opinion in Grecian Magnesite (Grecian Magnesite Mining…

Monte A Jackel in Jackeltaxlaw

Jan 16, 2023

Regulation Examples Not Supported By Text: A Partnership Response

In his interesting recent Tax Notes article on regulation examples being promulgated without supporting regulatory text (Jasper L. Cummings, “Regulation Examples Are Not Guidance”, Tax Notes Federal, Jan. 16, 2023…

These were the top 10 stories published by Jackeltaxlaw; you can also dive into yearly archives: 2022, 2023.

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