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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...

Status Update on Targeted Allocation Regulations

By Amanda Wilson on Sep 18, 2015 in Other, code, International, IRS, targeted allocations, Tax

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...

IRS No Rule Policy Expected to Cool Down Spin-offs

By Amanda Wilson on Sep 16, 2015 in Other, Real estate, International, IRS, REIT, treasury

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)...