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Internal Revenue Service Insolvency

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
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

Troutman Pepper

How Can I Claim a Business Bad Debt Deduction? - Creditor's Rights Toolkit

Troutman Pepper on

The Internal Revenue Code permits a business bad debt deduction when a customer fails to pay for the services rendered or the products supplied by your business. However, the ability to claim an ordinary deduction with...more

Rivkin Radler LLP

Sale of Mortgaged Property – Amount Realized or COD Income

Rivkin Radler LLP on

Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”? I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized....more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

Rivkin Radler LLP on

Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

Freeman Law

Tax Court in Brief | Patacsil v. Comm’r | Insolvency to Avoid Recognition of Cancellation-of-Indebtedness income; Net Operating...

Freeman Law on

Summary: Ernesto Patacsil and Marilyn Patacsil (“Taxpayers”) owned a business that ran group homes for consumers with intellectual or physical maladies in California, being an expensive yet statutorily encouraged...more

Farrell Fritz, P.C.

Virus To Economic Shutdown To Bankruptcy? Not Necessarily, But Be Prepared

Farrell Fritz, P.C. on

Bankruptcy Resurgent? The economic shutdown, and the ensuing recession, triggered by the COVID-19 pandemic have jeopardized the survival of many businesses and, in some cases, of entire industries. Notwithstanding the...more

Kramer Levin Naftalis & Frankel LLP

Debt Dialogue: August 2017 - The IRS Withdraws Proposed ‘Net Value’ Regulations

The IRS announced in July that it has withdrawn proposed regulations (the net value regulations) that provided guidance regarding corporate formations, reorganizations and liquidations of insolvent corporations. Those...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 9, No. 2

Editor's Note - Welcome to Tax Talk 9.02. By this fall, we may look back on Q2 2016 with some nostalgia. Of course, there is the U.S. presidential election on November 8th, but U.S. tax advisors right now are more...more

McGuireWoods LLP

IRS, PBGC Issue Guidance on Multiemployer Plan Benefit Suspensions and Plan Partitions

McGuireWoods LLP on

Yesterday the Internal Revenue Service (IRS) and Pension Benefit Guaranty Corporation (PBGC) issued temporary, proposed and interim final regulations and a revenue procedure (collectively, the Guidance) under the...more

Bilzin Sumberg

Determining Foreigners Insolvency Exception

Bilzin Sumberg on

Can a foreign person exclude foreign-situs assets in determining insolvency exception to cancellation of indebtedness income? With the worldwide global default rate on corporate debt continuing to rise, a taxpayer’s...more

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