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Abstract: 

This installment of Short Takes begins with a relatively Long Take on a recent Ninth Circuit case holding that the Mandatory Repatriation Tax, a one-time tax that was part of the Tax Cuts and Jobs Act of 2017, was constitutional, a matter that should be of interest to investors. It then considers developments affecting several nonrecognition provisions, realization and related issues, and capitalization questions.

Keywords: income recognition, income realization, SALT cap, disallowed deductions, hobby loss deduction, passive activity losses, Administrative Procedures Act

Affiliations:  1: Journal of Taxation of Investments.