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    COD Information Reporting Rules Finalized

    Article The IRS issued final regulations regarding information returns for cancellation of indebtedness by certain entities.
    Published on January 28, 2011

    Incorporating an Insolvent Partnership Availability of the Insolvency Exclusion

    Article Incurring COD income at the partnership level may provide significantly different, and potentially detrimental, tax results to owners in a partnership than would incurring COD income at the corporate level
    Published on April 01, 2013

    Debt Discharge Under Sec. 108 Partnerships vs. S Corps.

    Article As tax liability for COD income gives many taxpayers an unpleasant surprise in today’s economy, its tax treatment continues to be a focal point for tax professionals in tax planning and preparation
    Published on November 30, 2012

    Impact of Anticipated COD Income on Investors Joining Existing Partnerships

    Article When appreciated property is contributed to a partnership, the precontribution gain is accounted for under Sec. 704(c), which provides that income, gain, loss, and deduction for property contributed to the partnership by a partner are shared among the partners so as to take account of the variation between the basis
    Published on January 28, 2011

    IRS Provides Guidance on Election to Defer COD Income

    Article The IRS has provided guidance to taxpayers on how to make the new election to defer recognizing cancellation of debt (COD) income under Sec. 108(i
    Published on January 28, 2011

    Receipt of Form 1099-C May Not Signal Taxable COD Income

    Article It is up to the taxpayer and his or her advisers to correctly identify the appropriate year in which to recognize COD income based on the date it is clear the debt will not be repaid
    Published on November 30, 2012

    Final Regs. on Acceleration of COD Income Deferral

    Article The IRS issued final regulations on the rules to accelerate COD income that taxpayers elected to defer over a five-year period when an applicable debt instrument was reacquired by the issuer or a related party in 2009 or 2010...
    Published on August 31, 2013

    Final Regs. Issued on Deferral of COD Income and OID Deductions

    Article The IRS issued final regulations on the application of Sec. 108(i), providing guidance to C corporations regarding the accelerated inclusion of deferred cancellation of debt income and accelerated deduction of deferred original issue discount.
    Published on October 31, 2013

    Should a Company Elect to Defer Cancellation of Debt

    Article The American Recovery and Reinvestment Act of 2009 provides certain business debtors with a cancellation of debt (COD) income deferral election under new Sec. 108(i) for reacquisitions by the debtor or by certain related parties of applicable debt instruments after December 31, 2008, and before January...
    Published on January 28, 2011

    Cancellation of Debt Income for Debtor Subsidiary Corporations

    Article This item addresses the U.S. corporate income tax effects of cancellation of debt (COD) income; the contribution-to-capital exception to COD income; partial cancellation of COD income; the impact of insolvency; and, finally, some COD income issues to consider in the international...
    Published on March 31, 2014

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