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Archive for Jorge Otoya

The House Passes Tax-Extenders Bill

On December 3, 2014, the House passed “The Tax Increase Prevention and Reconciliation Act of 2014” (TIPRA) by a vote of 378 to 46. This bill includes a temporary one-year extension of many favorable tax provisions and a laundry list of technical corrections, including extension of:

• The education deduction for teachers;

• Exclusion from taxable income of discharge of qualified principal residence indebtedness;

• Mortgage insurance premiums treated as a mortgage interest deduction; Read more

Treasury And IRS Issue Proposed Regulations On Disguised Sales And Partnership Liability Allocations

Summary

On January 30, 2014, Treasury and the IRS issued Proposed Regulations with respect to the disguised sale rules and the rules for allocating partnership liabilities (REG-119305-11). A major driving force behind these Proposed Regulations was the IRS’s victory in Canal Corporation and Subsidiaries, formerly Chesapeake Corporation and Subsidiaries v. Commissioner, 135 T.C. No. 9. (2010). In Canal, the Tax Court shot down a leveraged partnership structure by concluding that the contributing partner did not have a payment obligation with respect to the partner’s indemnity in large part because the terms of the indemnity were not commercially reasonable. Read more