Carried Interest in the Context of Venture Capitalists Business Bad Debt Deduction
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
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
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
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
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
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
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
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
Massachusetts Passes Economic Development Act
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
State and Federal NOL Rules Differ in Key Respects
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