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 I'm at the ABA Tax conference this week and one of this morning's first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries, discussed the...

By: Amanda Wilson On Monday, the IRS released Notice 2015-59. In it, the IRS announced that the IRS will no longer issue private letter rulings on whether a distribution satisfies the requirements of Section 355 for a tax-free spin-off where (i) the...