Administrative Law

Download Bankruptcy & insolvency taxation by Grant W. Newton PDF

By Grant W. Newton

The hundreds of thousands of mergers, acquisitions, and start-ups that experience characterised the previous ten years of commercial have created a growing number of enterprises in monetary difficulty: in particular, a scarcity a bet capital or quickly money. therefore, financial disaster security is now considered as a strategic movement to guard firms from their collectors and make allowance them to reorganize. financial disaster and Insolvency Taxation, 3rd version offers the solutions to the questions monetary managers may have at the tax points of the "bankruptcy strategy."

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2d 122 (1st Cir. 1946); Commissioner v. 2d 382 (1st Cir. 1944). C. section 108(e)(10), Treas. Reg. 108-1, Alcazar Hotel, Inc. v. C. 872 (1943); Rev. Rul. B. 34; Rev. Rul. B. 198; Rev. Rul. B. 80; Private Letter Ruling 8852039 (Oct. 4, 1988); Lipton, Debt-Equity Swap for Parent-Subsidiary: A Current Analysis of a Useful Technique, 59 J. Tax’n 406 (1983). 7(a). The repeal of the stock-for-debt exception applies to stock transferred after December 31, 1994. Later transfers will continue to be subject to the stock-for-debt exception only if they were made pursuant to title 11 or similar cases filed on or before December 31, 1993.

Reg. 108-2(c)(5). 66 n 37 n Discharge of Indebtedness establish that the holder did not acquire the indebtedness in anticipation of becoming related to the debtor. C. section 108(e)(4). In the preamble to the proposed Treas. Reg. C. sections 332, 351, 368, 721, and 731. The preamble also provides: In general, if assets are transferred in a tax-free transaction and the transferee receives the assets with a carryover (or, in certain cases, a substituted) basis, any built-in income or gain is taxed when the transferee disposes of the asset.

Applicable law. We will never know. The Tax Court’s short shrift approach, completely discarding the characterization of the income as discharge of indebtedness, is not a recommended analysis. Although the characterization of the income may not have made a difference under the facts of the case, it could easily have significant implications if the debtor were in bankruptcy or insolvent. (b) Is the Obligation Indebtedness? Another threshold issue is whether the obligation is “indebtedness” for federal income tax purposes.

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