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    Carried Interest in the Context of Venture Capitalists Business Bad Debt Deduction

    Article The Tax Court held that a venture capitalist’s $3.6 million bad debt was incurred in connection with his carrying on a trade or business of managing venture capital funds and was fully deductible as an ordinary loss under Sec. 166(a).
    Published on September 01, 2011

    Tiered Partnerships Will Net Investment Income Tax and Proposals to Change Taxation of Carried Interests Wreak Havoc

    Article Tiered partnerships could become subject to ordinary income tax treatment on many forms of revenue that had previously enjoyed a lower capital gain tax rate.
    Published on August 01, 2013

    Navigating the Net Investment Income Tax Key Issues for Investment Funds and Their Partners

    Article This item summarizes the aspects of the net investment income tax that are most relevant to hedge fund investors and general partners.
    Published on October 01, 2014

    The Targeted Allocations Approach A Basic Primer

    Article This item discusses a growing trend in the allocation provisions of partnership agreements in which limited partnerships have been adopting a targeted allocation approach through which “tax follows cash.”
    Published on October 01, 2011

    Disposing of an Activity to Release Suspended Passive Losses

    Article Unused PALs are suspended and carried forward to future years until the taxpayer (1) disposes of the particular activity that generated the losses, (2) generates net passive activity income in the case of a personal...
    Published on May 01, 2008

    Lack of Limitation Period on Certain Adjustments Affirmed in Recent Decision

    Article A recent case illustrates that courts may sustain the government when it makes adjustments to closed years only to determine whether an overpayment of tax exists, and not to recover additional taxes beyond the limitation period on assessment.
    Published on July 01, 2010

    Mitigating the Results of a Failure to Carry Back an NOL

    Article This item discusses how a taxpayer, when making a decision about when to use a net operating loss (NOL), can ensure that it is carried back and/or forward properly
    Published on August 01, 2011

    2009 Tax Software Survey

    Article The Tax Adviser and the Journal of Accountancy conducted a survey of their readers to determine what aspects of their tax preparation software they like and what they dislike.
    Published on September 01, 2009

    State and Federal NOL Rules Differ in Key Respects

    Article State net operating loss (NOL) rules generally differ from federal NOL rules, and state NOL rules often differ from one another. This lack of consistency can lead to confusion about a taxpayer’s ability to utilize NOLs.
    Published on July 01, 2010

    Massachusetts Passes Economic Development Act

    Article This item reviews the 2010 Massachusetts Economic Development Reorganization Act, which made significant reforms and clarifications to Massachusetts tax law.
    Published on December 01, 2010

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