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@andreacpa0@andreacpa0 check the j-6 regs under partner level treatment of carryovers, EBI reduces outside basis, further EBIE disallowed from PY, CY deductible Biz Int, and CY EBI form one loss group under 704(d). However if partners outside basis increases in subsequent year any
@andreacpa0 Deductible biz interest is taken into account first. So it’s possible the partner allocated ETI in that same year may not be able to deduct EBIE from PY. My other recommendation is to order another 🥃 before reading more 163(j) regs
@nittiaj I want a definition of a “small-business” taxpayer for BIE limitation, but also hesitant since I said the same thing about RRE ToBs for 199A but instead we got Notice 2019-07 safe-harbor
@RyanJMcDonell@nittiaj That’s how I’m reading it, I’m also wondering why the partner includes its allocable share of the partnerships depreciation and amortization in ATI.
@nittiaj As a colleague pointed out to me and some more time to digest the regs I could be over analyzing the election. it’s still not clear that an electing RP tob can’t treat the assets PIS prior to 1/1/18 as excepted assets
@nittiaj The allocation rules of 1.163(j)-10 require interest expense of debt secured by real property to be directly traced to the assets. Therefore I think the inability to make a retroactive election for all acquisitions placed into service prior to the effective date cont.
@Iberia@AmericanAir my sister in law @ForbesGreene is trying to track down her luggage that you guys lost on the way to HER HONEYMOON!!! She keeps calling and getting bounced around with no explanation. Please help!!!@Iberia_en @ibexpress_help