The Willens Reportsm

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"Processing" a Natural Resource
June 24, 2016
X, a publicly-traded partnership, (MLP or PTP), owns and operates an aluminum smelter. The production of aluminum involves three steps, the last of which happens to b...

"Robert Willens LLC is neither a registered investment advisor nor a broker/dealer. Subscribers and/or readers are advised that the information contained in The Willens Report is not to be construed or relied upon as investment, tax planning, accounting and/or legal advice, nor is it to be construed in any way as a recommendation to buy, hold or sell (short or otherwise) any security or any other form of investment. All opinions, analyses and information contained herein is based upon sources believed to be reliable and is written in good faith, but no representation or warranty of any kind, express or implied, is made herein concerning any investment, tax, accounting and/or legal matter or the accuracy, completeness, correctness, timeliness and/or appropriateness of any of the information contained herein. Subscribers and/or readers are further advised that the Company does not necessarily update the information and/or opinions set forth in this and/or any subsequent edition of The Willens Report or any version thereof. Readers are urged to consult with their own independent professional advisors with respect to any matter analyzed herein. All information contained herein and/or this website should be independently verified."


Recent Reports

Calculating The Sec. 108(c) Exclusion Amount
June 23, 2016
TP owns two items of real property used in a trade or business, Property A and Property B. At the time of the debt forgiveness, Property A had a fair market value of "$a&q...
Amortizable Sec. 197 Intangibles
June 22, 2016
A, married individuals, began operating a cardroom and entertainment business as a partnership. Eventually, A incorporated the business, operating a restaurant and ca...
Latham & Watkins Will Not Be Deterred
June 21, 2016
Apparently, yesterday, at the hearing conducted in Delaware Chancery Court regarding the WMB/ETE deal, we had a rare "Court Holding Company" sighting. This...
Pennsylvania's "Sec. 382 Limitation" Is Unconstitutional
June 21, 2016
Taxpayer ("TP") is a Delaware corporation with headquarters in New York. TP was wholly owned by R corporation, and R corporation, in turn, was wholly owned by RBA cor...