By Jonathan Prokup and David Shakow You might recall our prior post on the Wyden-Gregg tax reform proposal in which we discussed the proposed limitation on corporate interest deductions. To summarize, the legislation would limit the deductibility of payments on corporate debt to the amount of the interest in excess of the annual rate of … More More on Wyden-Gregg’s Interest Disallowance Rule
By Jonathan Prokup and David Shakow We previously discussed how the Wyden-Gregg bill proposes reducing interest deductions to the extent the interest simply compensates for inflation. Inflation affects tax calculations in two ways. First, it affects the dollar figures in the Code so that, for example, when your wages keep up with inflation, but you … More The Wyden-Gregg Tax Reform Bill – Part I (cont’d)
By Jonathan Prokup In her column last Monday, Lee Sheppard criticized Judge Holmes of the Tax Court for, as she put it, “strain[ing] to find a reason to hold for the taxpayer” in the recent case of Container Corp. v. Comm’r, 134. T.C. No. 5. (For our prior discussion of this case, see here. For … More Lee Sheppard Takes on Container Corp.