Monte Jackel Quoted in Tax Notes Today on Partnership and Consolidated Return Tax Rules

Tax Notes Today has quoted Monte Jackel, senior counsel at Akin Gump, in the article “Partnership Basis Stripping Inside a Consolidated Return,” which looks at a recent IRS internal legal memorandum about the intersection of the partnership rules and the consolidated return rules.

Jackel compares the two rules, questioning whether the special partnership rule for a corresponding adjustment to the basis of assets of a distributed corporation controlled by a corporate partner should have applied when the acquired corporation became a member of the taxpayer group. He also discusses the intercompany transaction antiabuse rule, which grants the power to recharacterize a taxpayer transaction or its income tax effects.