Taxing times blog header

Worthless Debt Deduction - A Cautionary Tale

By Amanda Wilson on Oct 7, 2015 in Other, International, IRS, tax court, tax return

By:  Amanda Wilson For partnership, individuals and other types of taxpayers that are not in the business of making loans, the main avenue for tax relief when a loan goes bad is Section 166 - the bad debt deduction.  In order to claim this...

IRS Finalizes Regs on F Reorgs

By Amanda Wilson on Sep 24, 2015 in Other, International, irc, IRS

By: Amanda Wilson The IRS has finalized its regulations  on Section 368(a)(1)(F) reorganizations.  An F reorganization is characterized as a mere change in the identity, form, or place of organization of one corporation. The final regulations...

Senators Call on IRS to Finalize Management Fee Waiver Regulations

By Amanda Wilson on Sep 23, 2015 in Congress, government, International, irc, IRS, medical marijuana, Partnership Tax, treasury

By:  Amanda Wilson Yesterday, Senators Franken, Warren, Baldwin and Whitehouse sent Treasury Secretary Lew a letter regarding management fee waiver arrangements. What is a management fee waiver arrangement?  It is where a fund manager waives its...

Carried Interests OK Under Management Fee Waiver Regulations

By Amanda Wilson on Sep 21, 2015 in carried interest, code, International, IRS, regulations, treasury

By:  Amanda Wilson Last week, I was at the ABA Tax Section meeting in Chicago.  During one of the partnership panels, Clifford Warren, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries) at the IRS, was posed several...