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Tax Liability Cancellation of Debt (COD) Internal Revenue Service

Pillsbury Winthrop Shaw Pittman LLP

Commercial Real Estate Partnership Cancellation of Debt Income

The complexities of cancellation of debt income (CODI), including bankruptcy and insolvency implications, are important to understand. When debt is cancelled or discharged, the borrowed funds become taxable income, or...more

Rivkin Radler LLP

Bona Fide Intercompany Loan – Are You Sure?

Rivkin Radler LLP on

Head-Scratchers- The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic...more

Cadwalader, Wickersham & Taft LLP

IRS Issues Taxpayer-Favorable Debt Workout Ruling

In PLR 202050014, the IRS ruled that a parent would not recognize taxable gain when its disregarded entity transferred a newly formed corporation’s stock to creditors in satisfaction of its debt pursuant to a “G”...more

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