Tax Blog/Blawg

Two weeks ago, the Fifth Circuit summarily rejected a taxpayer request for an en banc rehearing in Southgate Master Fund LLC v. United States.  The appellate court had previously concluded that the taxpayer was not entitled to a claimed capital loss from a transaction involving the acquisition of distressed debt via a partnership because the partnership was a “sham” that should be disregarded for federal tax purposes.  The taxpayer's petition for rehearing, along with two amicus briefs, raised the specter that the Fifth Circuit's opinion would require taxpayers to have a non-tax ...

According to the Financial Times, companies around the world are preparing for the possibility of a breakup of the euro.  Given the currency devaluation that would likely occur in countries coming out of the euro, these companies are preparing for the impact that such an event would have on balance sheets (e.g., asset prices) and income statements (e.g., import costs).   (For additional FT coverage of the issue, see here.)

As we noted in the TaxBlawg a while back when the euro crisis was still focused primarily on Greece, a partial or complete breakup of the eurozone would give rise to a host ...

Now that the tax extenders legislation has died, what’s next?  At least some of the provisions (e.g., the new tax regime for “carried interests”) are likely to find their way into future legislation.  But what about the tax extenders themselves, such as the look-through rule of section 954(c)(6) and the section 41 research credit?  Although many of the extensions involve tax expenditures (i.e., provisions that cost the Treasury money), they would almost certainly be offset by the bill’s revenue raisers, which were themselves styled as anti-abuse and loophole-closing provisions.  As a result, we probably have not seen the last of these measures.