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 deduction,...

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 provide...

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...

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...